Helvering v. Horst

E61236

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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Statements (43)

Predicate Object
instanceOf United States Supreme Court case
assignment of income doctrine case
federal income tax case
appliedBy United States Tax Court
federal courts of appeals
appliesTo United States federal income tax
areaOfLaw federal tax law
income tax
category United States Supreme Court cases in taxation
United States Supreme Court cases of the Hughes Court
citation 311 U.S. 112
61 S. Ct. 144
85 L. Ed. 75
clarified tax consequences of separating income from the property that generates it
concernedIncomeType interest coupons from bonds
concernedProperty negotiable bonds
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1940-12-09
holding the donor of interest coupons who retained ownership of the bonds was taxable on the interest income paid to the donee
impact limited taxpayers’ ability to shift income to lower-bracket family members by assignment
strengthened the assignment of income doctrine in U.S. tax law
issue whether a taxpayer who gives interest coupons from bonds to another person is taxable on the interest when paid
jurisdiction United States federal jurisdiction
keyConcept anticipatory assignment of income
ownership and control over income source
realization of income
languageOfWork English
legalDoctrine assignment of income doctrine
legalPrinciple a taxpayer cannot avoid income tax by assigning the right to receive income while retaining ownership of the underlying property
income is taxed to the person who earns it or who owns the property that produces it
majorityOpinion held that the power to dispose of income is the equivalent of ownership of it for tax purposes
majorityOpinionBy Justice Stone
petitioner Guy T. Helvering
precedentFor cases involving assignment of interest and dividend income
relatedCase Blair v. Commissioner
Helvering v. Eubank
Lucas v. Earl
respondent Horst
subjectMatter effect of anticipatory assignment of income
taxation of interest income from bonds
term United States Supreme Court cases of the Hughes Court
surface form: October Term 1940
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. Horst