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.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Helvering v. Horst canonical | 5 |
How this entity was disambiguated
This entity first appeared as the object of triple T486097 — 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. Horst Context triple: [Guy T. Helvering, notableWork, Helvering v. Horst]
-
A.
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.
-
B.
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.
-
C.
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.
-
D.
Frohwerk v. United States
Frohwerk v. United States is a 1919 U.S. Supreme Court case in which the Court upheld a conviction for antiwar newspaper articles, reinforcing broad federal power to punish speech deemed obstructive to World War I military recruitment.
-
E.
Helvering
Helvering is a surname most notably associated with Guy T. Helvering, a prominent American politician and former Commissioner of Internal Revenue.
- 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. Horst Target entity description: 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.
-
A.
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.
-
B.
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.
-
C.
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.
-
D.
Frohwerk v. United States
Frohwerk v. United States is a 1919 U.S. Supreme Court case in which the Court upheld a conviction for antiwar newspaper articles, reinforcing broad federal power to punish speech deemed obstructive to World War I military recruitment.
-
E.
Helvering
Helvering is a surname most notably associated with Guy T. Helvering, a prominent American politician and former Commissioner of Internal Revenue.
- F. None of above. chosen
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
ⓘ
linked to:
United States of America
|
| 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 | October Term 1940 ⓘ |
| yearDecided | 1940 ⓘ |
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. Horst Description of subject: 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.
Referenced by (5)
Full triples — surface form annotated when it differs from this entity's canonical label.