Helvering v. Bruun, 309 U.S. 461 (1940), was an income tax case before the Supreme Court of the United States. It is notable (and thus appears frequently in law school casebooks) for holding that under section 22(a) of the Revenue Act of 1932, a landlord realizes a taxable gain when he repossesses property, the value of which has increased because the property was improved by a tenant. Facts A landlord repossessed land from a tenant who had defaulted in the eighteenth year of a 99-year lease. During the course of the lease, the tenant had torn down an old building (in which the landlord's adjusted basis was now $12,811.43) and had built a new one (whose value was now $64,245.68). The lease had specified that the landlord was not required to compensate the tenant for these improvements. The government argued that upon repossession, the landlord realized a gain of $51,434.25. The landlord argued that there was no realization of the property because no transaction had occurred, and because the improvement of the property that created the gain was not "severable" from the landlord's original capital. Holding The court held for the government: under the Revenue Act of 1932, the value of the improvements was realized by the taxpayer as income in the year in which the forfeiture occurred. The improvements, the Court observed, were received by the taxpayer "as a result of a business transaction," namely, the leasing of the taxpayer's land. It was not necessary to the recognition of gain that the improvements be severable from the land. All that had to be shown was that the taxpayer had acquired valuable assets from his lease in exchange for the use of his property. The medium of exchange—whether cash or in kind, and whether separately disposable or "affixed"—was immaterial as far as the realization criterion was concerned. In effect, the improvements represented rent, or rather a payment in lieu of rent, which was taxable to the landlord regardless of the form in which it was received. "Severance" is not necessary for realization: It is not necessary to recognition of taxable gain that he should be able to sever the improvement begetting the gain from his original capital. If that were necessary, no income could arise from the exchange of property, whereas such gain has always been recognized as realized taxable gain. The Court added that, while not all economic gain