Helvering v. Clifford
E61712
Helvering v. Clifford is a landmark 1940 U.S. Supreme Court tax law case that clarified when income from a trust should be attributed to the grantor for federal income tax purposes.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Helvering v. Clifford canonical | 3 |
How this entity was disambiguated
This entity first appeared as the object of triple T486098 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Helvering v. Clifford Context triple: [Guy T. Helvering, notableWork, Helvering v. Clifford]
-
A.
Helvering v. Horst
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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B.
Helvering v. Bruun
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.
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C.
Helvering v. Davis
Helvering v. Davis is a 1937 U.S. Supreme Court case that upheld the constitutionality of the Social Security Act and broadly affirmed federal power to tax and spend for the general welfare.
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D.
Schechter Poultry Corp. v. United States
Schechter Poultry Corp. v. United States is a 1935 U.S. Supreme Court case that struck down key provisions of the New Deal by limiting federal power under the Commerce Clause and declaring the National Industrial Recovery Act unconstitutional.
-
E.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Helvering v. Clifford Target entity description: Helvering v. Clifford is a landmark 1940 U.S. Supreme Court tax law case that clarified when income from a trust should be attributed to the grantor for federal income tax purposes.
-
A.
Helvering v. Horst
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.
-
B.
Helvering v. Bruun
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.
-
C.
Helvering v. Davis
Helvering v. Davis is a 1937 U.S. Supreme Court case that upheld the constitutionality of the Social Security Act and broadly affirmed federal power to tax and spend for the general welfare.
-
D.
Schechter Poultry Corp. v. United States
Schechter Poultry Corp. v. United States is a 1935 U.S. Supreme Court case that struck down key provisions of the New Deal by limiting federal power under the Commerce Clause and declaring the National Industrial Recovery Act unconstitutional.
-
E.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
- F. None of above. chosen
Statements (42)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
federal income tax case ⓘ grantor trust case ⓘ tax law case ⓘ |
| appliedPrinciple | substance over form in tax law ⓘ |
| appliesTo |
short-term family trusts
ⓘ
situations where grantor retains control over trust corpus ⓘ situations where grantor retains economic benefits of trust property ⓘ |
| clarified |
federal income tax treatment of revocable or highly controlled trusts
ⓘ
when income from a trust should be attributed to the grantor ⓘ |
| concerns |
allocation of trust income between grantor and beneficiaries
ⓘ
federal income taxation of trusts ⓘ |
| establishedDoctrine | Clifford trust doctrine ⓘ |
| hasAreaOfLaw |
tax law
ⓘ
trusts and estates ⓘ |
| hasCitation | 309 U.S. 331 ⓘ |
| hasCountry |
United States of America
ⓘ
surface form:
United States
|
| hasCourt | Supreme Court of the United States ⓘ |
| hasDateDecided | March 11, 1940 ⓘ |
| hasHolding |
formal transfer of legal title to a trustee does not alone determine tax liability
ⓘ
income of a trust may be taxable to the grantor if the grantor retains substantial control or economic benefits ⓘ |
| hasJurisdiction | United States federal law ⓘ |
| hasLanguage | English ⓘ |
| hasLegalIssue |
attribution of trust income to grantor for federal income tax purposes
ⓘ
grantor trust doctrine ⓘ whether short-term family trust income is taxable to the grantor ⓘ |
| hasOpinionBy | Justice Harlan F. Stone ⓘ |
| hasPetitioner |
Guy T. Helvering
ⓘ
surface form:
Guy T. Helvering, Commissioner of Internal Revenue
|
| hasPrecedentialStatus | binding precedent in U.S. federal courts on grantor trust issues ⓘ |
| hasRespondent | Clifford ⓘ |
| hasResult | trust income in question was taxable to the grantor ⓘ |
| hasTimePeriod | 20th century ⓘ |
| hasYearDecided | 1940 ⓘ |
| influenced |
Internal Revenue Code grantor trust provisions
ⓘ
later Supreme Court tax cases on substance over form ⓘ |
| isCitedFor |
analysis of retained control and enjoyment in trust arrangements
ⓘ
criteria for attributing trust income to grantor ⓘ definition of grantor trust ⓘ |
| isLandmarkFor |
U.S. federal income tax law
ⓘ
grantor trust rules ⓘ |
| isTaughtIn |
U.S. federal income tax courses
ⓘ
trusts and estates law courses ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Helvering v. Clifford Description of subject: Helvering v. Clifford is a landmark 1940 U.S. Supreme Court tax law case that clarified when income from a trust should be attributed to the grantor for federal income tax purposes.
Referenced by (3)
Full triples — surface form annotated when it differs from this entity's canonical label.