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.
All labels observed (3)
| Label | Occurrences |
|---|---|
| Helvering v. Bruun canonical | 2 |
| Helvering v. Bruun, 309 U.S. 461 (1940) | 1 |
| Supreme Court decision in Helvering v. Bruun (1940) | 1 |
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 (4)
Full triples — surface form annotated when it differs from this entity's canonical label.
this entity surface form:
Helvering v. Bruun, 309 U.S. 461 (1940)
this entity surface form:
Supreme Court decision in Helvering v. Bruun (1940)