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.
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.