Premise: Helvering v. Horst, 311 U.S. 112 (1940) , is an opinion of the United States Supreme Court which further developed the “fruit-and-tree” metaphor established in "Lucas v. Earl", 281 U.S. 111 (1930) . "Horst" is the leading case that applies the assignment of income doctrine to income from property.
Hypothesis: "Lucas v. Earl" was before "Helvering v. Horst."