Helvering v. Bruun

E60924

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.


Statements (44)
Predicate Object
instanceOf United States Supreme Court case
federal income tax case
landmark tax law case
appliedStatute Internal Revenue Code provisions on gross income
areaOfLaw federal taxation of income
tax law
bindingAuthorityIn federal judiciary of the United States
surface form: "federal courts of the United States"
category 1940 in United States case law
United States Supreme Court cases
United States taxation case law
citation 309 U.S. 461
clarifiedConcept realization of gain without a sale or exchange
taxability of non-cash economic benefits
concerns tax consequences of lease termination
valuation of improvements for income tax purposes
constitutionalContext Sixteenth Amendment to the United States Constitution
country United States of America
court Supreme Court of the United States
decisionDate 1940-01-29
factPattern Landlord repossessed leased land after tenant constructed a new building on the property
Lease was terminated and landlord regained possession of improved property
holding A landlord realizes taxable income when repossessing property that has been enhanced in value by improvements made by a tenant
The increase in value attributable to tenant-made improvements can constitute realized income to the landlord upon repossession
impact Influenced later interpretations of realization and gross income in U.S. tax law
issue Whether a landlord realizes taxable income upon repossession of leased property that has been improved by the tenant
jurisdiction United States of America
surface form: "United States"
language English
legalPrinciple Gain may be realized when a taxpayer obtains possession of property that has increased in value due to another’s improvements
legalSubject federal income tax
landlord-tenant law
real property taxation
realization of income
page 461
petitioner Guy T. Helvering
petitionerRole Commissioner of Internal Revenue
precedentFor realization doctrine in U.S. federal income tax
relatedCase Commissioner v. Glenshaw Glass Co.
Eisner v. Macomber
relatedConcept accession to wealth
gross income under the Sixteenth Amendment
respondent Bruun
timePeriod 20th century
volume 309 U.S.
yearDecided 1940

Referenced by (1)

Full triples — surface form annotated when it differs from this entity's canonical label.

Guy T. Helvering notableWork Helvering v. Bruun

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