Helvering v. Horst

United States Supreme Court

311 U.S. 112 (1940)

A gift of interest coupons detached from bonds constitutes realized income to the donor.

Relevant Facts

Horst (the plaintiff) owned negotiable bonds which entitled the plaintiff to receive both the principal investment upon maturity and periodic interest payments. The amount of interest payments and their due date were specified on detachable interest coupons. The plaintiff gifted the coupons to his son before they became due. Helvering, commissioner of internal revenue (the defendant) determined that the interest payments were taxable income to the plaintiff.

The Board of Tax Appeals held in favor of the defendant. The Court of Appeals reversed and the United States Supreme Court granted certiorari.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 20, 2020

Judicial Opinion

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Procedural History

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Citations

311 U.S. 112 (1940)