Helvering v. Bruun
E60924
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.
All labels observed (3)
| Label | Occurrences |
|---|---|
| Helvering v. Bruun canonical | 2 |
| Helvering v. Bruun, 309 U.S. 461 (1940) | 1 |
| Supreme Court decision in Helvering v. Bruun (1940) | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T486096 — 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. Bruun Context triple: [Guy T. Helvering, notableWork, Helvering v. Bruun]
-
A.
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.
-
B.
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.
-
C.
Helvering
Helvering is a surname most notably associated with Guy T. Helvering, a prominent American politician and former Commissioner of Internal Revenue.
-
D.
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.
-
E.
United States v. Darby
United States v. Darby is a 1941 U.S. Supreme Court case that upheld federal labor regulations under the Commerce Clause and marked a broad expansion of federal power over economic activity.
- 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. Bruun Target entity description: 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.
-
A.
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.
-
B.
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.
-
C.
Helvering
Helvering is a surname most notably associated with Guy T. Helvering, a prominent American politician and former Commissioner of Internal Revenue.
-
D.
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.
-
E.
United States v. Darby
United States v. Darby is a 1941 U.S. Supreme Court case that upheld federal labor regulations under the Commerce Clause and marked a broad expansion of federal power over economic activity.
- F. None of above. chosen
Statements (44)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
federal income tax case ⓘ landmark tax law case ⓘ |
| appliedStatute | Internal Revenue Code provisions on gross income ⓘ |
| areaOfLaw |
federal taxation of income
ⓘ
tax law ⓘ |
| bindingAuthorityIn |
federal judiciary of the United States
ⓘ
surface form:
federal courts of the United States
|
| category |
1940 in United States case law
ⓘ
United States Supreme Court cases ⓘ United States taxation case law ⓘ |
| citation | 309 U.S. 461 ⓘ |
| clarifiedConcept |
realization of gain without a sale or exchange
ⓘ
taxability of non-cash economic benefits ⓘ |
| concerns |
tax consequences of lease termination
ⓘ
valuation of improvements for income tax purposes ⓘ |
| constitutionalContext | Sixteenth Amendment to the United States Constitution ⓘ |
| country | United States of America ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1940-01-29 ⓘ |
| factPattern |
Landlord repossessed leased land after tenant constructed a new building on the property
ⓘ
Lease was terminated and landlord regained possession of improved property ⓘ |
| holding |
A landlord realizes taxable income when repossessing property that has been enhanced in value by improvements made by a tenant
ⓘ
The increase in value attributable to tenant-made improvements can constitute realized income to the landlord upon repossession ⓘ |
| impact | Influenced later interpretations of realization and gross income in U.S. tax law ⓘ |
| issue | Whether a landlord realizes taxable income upon repossession of leased property that has been improved by the tenant ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| language | English ⓘ |
| legalPrinciple | Gain may be realized when a taxpayer obtains possession of property that has increased in value due to another’s improvements ⓘ |
| legalSubject |
federal income tax
ⓘ
landlord-tenant law ⓘ real property taxation ⓘ realization of income ⓘ |
| page | 461 ⓘ |
| petitioner | Guy T. Helvering ⓘ |
| petitionerRole | Commissioner of Internal Revenue ⓘ |
| precedentFor | realization doctrine in U.S. federal income tax ⓘ |
| relatedCase |
Commissioner v. Glenshaw Glass Co.
ⓘ
Eisner v. Macomber ⓘ |
| relatedConcept |
accession to wealth
ⓘ
gross income under the Sixteenth Amendment ⓘ |
| respondent | Bruun ⓘ |
| timePeriod | 20th century ⓘ |
| volume | 309 U.S. ⓘ |
| 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. Bruun Description of subject: 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.
Referenced by (4)
Full triples — surface form annotated when it differs from this entity's canonical label.
this entity surface form:
Helvering v. Bruun, 309 U.S. 461 (1940)
this entity surface form:
Supreme Court decision in Helvering v. Bruun (1940)