In the 1940 case of Helvering v. Horst, the U.S. Supreme Court addressed whether a taxpayer could avoid income tax by transferring interest coupons to another person before they were due. The respondent, Horst, had detached negotiable bond coupons from bonds he owned and gifted them to his son who collected them at maturity in the same year. The Commissioner of Internal Revenue argued that this was an attempt to shift taxable income away from its source and assessed a deficiency against him for not including these amounts in his gross income. The court ruled in favor of the Commissioner stating that even though legal title may have been transferred without compensation, economic benefit must be considered when determining what constitutes "income". It held that since Horst retained control over the sources producing receipts or accruals and made it possible for his son to receive them instead; he realized gain which is subject to taxation under Section 22(a) of Revenue Act (1936). This decision established what has become known as “the assignment-of-income doctrine”, asserting that one cannot avoid taxation through arrangements shifting enjoyment benefits derived from owning property or controlling its disposition.

In the dissenting opinion for Helvering v. Horst, Justice McReynolds disagreed with the majority's decision to tax a bond owner on interest that he had never received. He argued that this interpretation of income was too broad and inconsistent with previous rulings by the court. According to him, income should only be considered as such when it is fully realized by an individual or entity; in this case, since the bond owner gave away his right to receive interest before it accrued, he did not realize any gain from it and therefore should not be taxed on it. Furthermore, Justice McReynolds expressed concern about potential abuses of power if taxation were allowed based merely on control over sources of income rather than actual receipt or realization thereof.