Helvering v. Independent Life Ins. Co

Citation. Helvering v. Independent Life Ins. Co., 292 U.S. 371, 54 S. Ct. 758, 78 L. Ed. 1311, 4 U.S. Tax Cas. (CCH) P1290, 13 A.F.T.R. (P-H) 1175, 1934-1 C.B. 302, 1934 P.H. P1280 (U.S. May 21, 1934)

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CitationHelvering v. Independent Life Ins. Co., 292 U.S. 371, 54 S. Ct. 758, 78 L. Ed. 1311, 1934 U.S. LEXIS 715, 4 U.S. Tax Cas. (CCH) P1290, 13 A.F.T.R. (P-H) 1175, 1934-1 C.B. 302, 1934 P.H. P1280 (U.S. May 21, 1934)

Helvering v. Independent Life Ins. Co., 292 U.S. 371, 54 S. Ct. 758, 78 L. Ed. 1311, 1934 U.S. LEXIS 715, 4 U.S. Tax Cas. (CCH) P1290, 13 A.F.T.R. (P-H) 1175, 1934-1 C.B. 302, 1934 P.H. P1280 (U.S. May 21, 1934)

Brief Fact Summary. Petitioner owned and lived in a building, and was charged taxes on the rental value of the building.

Synopsis of Rule of Law. Rental value of a building used by the owner does not constitute income within the meaning of the Sixteenth Amendment.

Points of Law - Legal Principles in this Case for Law Students.

Congress has the power to condition, limit or deny deductions from gross income in order to arrive at the net that it chooses to tax.

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Facts. The majority of the facts are omitted from the text. Taxpayer argue that the Constitutional provision requiring apportionment of direct taxes precludes subjecting rental value of a building owned and occupied by Taxpayer to gross income.

Issue. Whether a taxpayer must include in gross income the rental value of a building owned and occupied by the taxpayer?

Held. The rental value of the building used by the owner does not constitute income within the meaning of the Sixteenth Amendment.

Discussion. The Court agreed that taxing the rental value of the property on the owner could violate the Constitutional provision requiring apportionment.

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