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.