Helvering v. Eubank
E296554
Helvering v. Eubank is a U.S. Supreme Court tax law decision addressing when income from assigned rights is taxable to the assignor rather than the assignee.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Helvering v. Eubank canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T2761785 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Helvering v. Eubank Context triple: [Helvering v. Horst, relatedCase, Helvering v. Eubank]
-
A.
Helvering v. Horst
Helvering v. Horst is a 1940 U.S. Supreme Court case that established key principles of the assignment of income doctrine in federal tax law.
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B.
Helvering v. Bruun
Helvering v. Bruun is a 1940 U.S. Supreme Court case that addressed whether a landlord realizes taxable income when repossessing property improved by a tenant.
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C.
Helvering v. Clifford
Helvering v. Clifford is a landmark 1940 U.S. Supreme Court tax law case that clarified when income from a trust should be attributed to the grantor for federal income tax purposes.
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D.
Helvering v. Gregory
Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions must have a genuine business purpose beyond tax avoidance to be respected for tax purposes.
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E.
Helvering v. Davis
Helvering v. Davis is a 1937 U.S. Supreme Court case that upheld the constitutionality of the Social Security Act and broadly affirmed federal power to tax and spend for the general welfare.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Helvering v. Eubank Target entity description: Helvering v. Eubank is a U.S. Supreme Court tax law decision addressing when income from assigned rights is taxable to the assignor rather than the assignee.
-
A.
Helvering v. Horst
Helvering v. Horst is a 1940 U.S. Supreme Court case that established key principles of the assignment of income doctrine in federal tax law.
-
B.
Helvering v. Bruun
Helvering v. Bruun is a 1940 U.S. Supreme Court case that addressed whether a landlord realizes taxable income when repossessing property improved by a tenant.
-
C.
Helvering v. Clifford
Helvering v. Clifford is a landmark 1940 U.S. Supreme Court tax law case that clarified when income from a trust should be attributed to the grantor for federal income tax purposes.
-
D.
Helvering v. Gregory
Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions must have a genuine business purpose beyond tax avoidance to be respected for tax purposes.
-
E.
Helvering v. Davis
Helvering v. Davis is a 1937 U.S. Supreme Court case that upheld the constitutionality of the Social Security Act and broadly affirmed federal power to tax and spend for the general welfare.
- F. None of above. chosen
Statements (32)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
federal income tax case ⓘ tax assignment of income case ⓘ |
| appliesDoctrine |
assignment of income from services
ⓘ
substance over form ⓘ |
| areaOfLaw |
federal income tax
ⓘ
tax law ⓘ |
| category |
United States Supreme Court cases in tax law
ⓘ
United States federal taxation case law ⓘ |
| citationStatus | leading case on assignment of income ⓘ |
| clarifies | that the power to dispose of income is equivalent to ownership for tax purposes ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| holding | income from assigned rights remained taxable to the assignor ⓘ |
| influenced | later U.S. federal income tax assignment-of-income cases ⓘ |
| jurisdiction | United States federal law ⓘ |
| language | English ⓘ |
| legalIssue |
assignment of income doctrine
ⓘ
taxation of assigned income ⓘ |
| party |
Eubank
ⓘ
Helvering ⓘ |
| petitioner | Helvering ⓘ |
| principle |
a taxpayer cannot escape tax by assigning the right to receive income while retaining the source of that income
ⓘ
income is taxed to the person who earns it or who owns the property that produces it ⓘ |
| relatedConcept |
anticipatory assignment of income
ⓘ
taxation of income from property ⓘ taxation of income from services ⓘ |
| respondent | Eubank ⓘ |
| result | assigned renewal commissions were taxable to the assignor ⓘ |
| subjectMatter |
federal income taxation of insurance renewal commissions
ⓘ
tax consequences of assigning contract rights to income ⓘ |
| usedFor | interpreting when income is taxable to the assignor rather than the assignee ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Helvering v. Eubank Description of subject: Helvering v. Eubank is a U.S. Supreme Court tax law decision addressing when income from assigned rights is taxable to the assignor rather than the assignee.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.