Helvering v. Eubank

Summary

The Supreme Court reversed the lower courts and held that renewal commissions assigned before the taxable year are includable in the assignor’s gross income in the year the commissions are paid to the assignee, following the reasoning of Helvering v. Horst. The Court based its decision on the statutory language of § 22 of the Revenue Act and the principle that an assignment of a right to future earnings does not relieve the taxpayer from taxation on the earnings. Justice McReynolds dissented, arguing that the assigned right is a property interest and should not be taxed to the assignor.