Helvering v. Horst

The sole question for decision is whether the gift, during the donor’s taxable year, of interest coupons detached from the bonds, delivered to the donee and later in the year paid at maturity, is the realization of income taxable to* the donor. . ”

'lh~1934 and 1935 respondent, the owner of negotiable bonds, detached from them negotiable interest coupons shortly before their due date and delivered them as a gift to his son who in the same year collected them at maturity. The Commissioner ruled that under the applicable | 22 of the Revenue Act of 1934, 48 Stat. 680, 686, the interest payments…