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Helvering v. Horst

United States Supreme Court

311 U.S. 112 (1940)

Relevant factsFree

Horst (plaintiff) owned negotiable bonds entitling him to principal at maturity and periodic interest paid via detachable coupons. He gave the coupons to his son before they came due. The Commissioner (defendant) determined the interest payments were taxable income to Horst.

IssueFree

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

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