From our private database of 28,700+ case briefs...
Hellermann v. Commissioner
United States Tax Court
77 T.C. 1361 (1981)
The Hellermanns (plaintiffs) bought four buildings for approximately $93,000 and sold the buildings 12 years later for $264,000. They reported a capital gain of approximately $170,000 on their tax return the year of the sale. Later, the Hellermanns claimed that much of the gain from the sale of the buildings was due to inflation, and they requested a refund of the capital-gains tax they paid. In the years between the purchase and sale of the buildings, the Consumer Price Index had doubled. Thus, the Hellermanns concluded, the economic gain from the sale was closer to $88,000. The Hellermanns argued that they should be taxed on their economic gain, not on their total capital gain, because the gain that was attributable to inflation was a return of capital and not taxable income. In their view, taxing the capital gain that was solely attributable to inflation violated the Sixteenth Amendment to the United States Constitution because it was a direct tax, not an income tax. The Hellermanns further argued that Congress did not have the power to measure capital gains in terms of dollars because the value of the dollar changes. The Commissioner of Internal Revenue (the Commissioner) (defendant) held that capital gains from the property sale were taxable income regardless of the actual economic value of the sale. The Hellermanns petitioned the United States Tax Court for a redetermination.
Rule of Law
Holding and Reasoning (Ekman, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 546,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 546,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 28,700 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.