Blair v. Commissioner
E296555
Blair v. Commissioner is a U.S. Supreme Court tax law case that addressed the assignment of income doctrine, holding that a taxpayer who assigns a beneficial interest in a trust also shifts the tax liability on the income from that interest.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Blair v. Commissioner canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T2761786 — 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: Blair v. Commissioner Context triple: [Helvering v. Horst, relatedCase, Blair v. Commissioner]
-
A.
Helvering v. Gregory
Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions must have a genuine business purpose beyond tax avoidance to be respected for tax purposes.
-
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.
Helvering v. Clifford
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.
-
D.
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.
-
E.
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.
- 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: Blair v. Commissioner Target entity description: Blair v. Commissioner is a U.S. Supreme Court tax law case that addressed the assignment of income doctrine, holding that a taxpayer who assigns a beneficial interest in a trust also shifts the tax liability on the income from that interest.
-
A.
Helvering v. Gregory
Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions must have a genuine business purpose beyond tax avoidance to be respected for tax purposes.
-
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.
Helvering v. Clifford
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.
-
D.
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.
-
E.
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.
- F. None of above. chosen
Statements (45)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
federal income tax case ⓘ tax law case ⓘ |
| appliesTo | beneficial interests in trusts ⓘ |
| appliesToTax | U.S. federal income tax ⓘ |
| areaOfLaw |
federal income tax
ⓘ
tax law ⓘ |
| category |
United States Supreme Court cases
ⓘ
surface form:
United States Supreme Court cases in tax law
United States Supreme Court cases involving trusts ⓘ United States federal income tax cases ⓘ |
| citationStatus | leading case on assignment of income involving trusts ⓘ |
| clarifies |
circumstances under which income tax liability follows an assigned beneficial interest
ⓘ
difference between assignment of income and assignment of property ⓘ |
| comparedWith | cases where only future income is assigned without transfer of the underlying interest ⓘ |
| concerns |
Commissioner of Internal Revenue
ⓘ
Internal Revenue Service ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| distinguishesFrom | mere assignment of income without transfer of underlying property interest ⓘ |
| effectOnTaxpayer | permits shifting of income tax liability when a genuine beneficial interest in a trust is transferred ⓘ |
| holding |
A taxpayer who assigns a beneficial interest in a trust also shifts the tax liability on the income from that interest
ⓘ
An effective assignment of a present beneficial interest in trust income causes the assignee, not the assignor, to be taxed on that income ⓘ |
| involves |
beneficiaries of a trust
ⓘ
transfer of equitable interest ⓘ |
| issue | Whether a taxpayer who assigns a beneficial interest in a trust remains taxable on the income from that interest ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| languageOfWork | English ⓘ |
| legalDoctrine | assignment of income doctrine ⓘ |
| legalEffect | recognizes validity of shifting tax liability with genuine transfer of beneficial interest ⓘ |
| petitioner | Blair ⓘ |
| principle |
Assignment of a present, vested beneficial interest in a trust can shift income tax liability to the assignee
ⓘ
Tax liability follows ownership of the underlying property interest that produces the income ⓘ |
| relevance |
interpretation of the assignment of income doctrine in U.S. federal tax law
ⓘ
tax planning involving trusts and assignments of beneficial interests ⓘ |
| respondent | Commissioner of Internal Revenue ⓘ |
| result |
assignee treated as owner of beneficial interest for income tax purposes
ⓘ
assignor not taxed on income from the assigned beneficial interest ⓘ |
| subjectMatter |
income tax liability after assignment of beneficial interest
ⓘ
taxation of trust income ⓘ |
| taxpayerAction | assignment of beneficial interest in a trust ⓘ |
| topic |
allocation of income for tax purposes
ⓘ
ownership of income-producing property for tax purposes ⓘ |
| typeOfIncome | trust income ⓘ |
| usedAsPrecedentIn | subsequent U.S. tax cases involving trust income assignments ⓘ |
| usedIn | analysis of whether income is taxable to assignor or assignee ⓘ |
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: Blair v. Commissioner Description of subject: Blair v. Commissioner is a U.S. Supreme Court tax law case that addressed the assignment of income doctrine, holding that a taxpayer who assigns a beneficial interest in a trust also shifts the tax liability on the income from that interest.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.