Evelyn F. Gregory
E360156
Evelyn F. Gregory was the taxpayer whose corporate reorganization scheme led to the landmark U.S. Supreme Court tax law case Helvering v. Gregory.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Evelyn F. Gregory canonical | 3 |
How this entity was disambiguated
This entity first appeared as the object of triple T2830195 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Evelyn F. Gregory Context triple: [Helvering v. Gregory, respondent, Evelyn F. Gregory]
-
A.
Fredricka G. Ross
Fredricka G. Ross is a songwriter best known for co-writing the lyrics to Alicia Keys’ hit ballad “Empire State of Mind (Part II) Broken Down.”
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B.
Dorothy E. Davis
Dorothy E. Davis was the lead student plaintiff in the Virginia school desegregation case Davis v. County School Board of Prince Edward County, one of the five cases consolidated into the landmark Supreme Court decision Brown v. Board of Education.
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C.
Dolores H. Russ
Dolores H. Russ was an American philanthropist and co-namesake of the prestigious Fritz J. and Dolores H. Russ Prize in engineering.
-
D.
Margaret C. Etter
Margaret C. Etter was an influential American chemist and crystallographer known for pioneering work in hydrogen bonding and crystal engineering.
-
E.
Phoebe A. Bass
Phoebe A. Bass was the wife of Hiram Revels, the first African American U.S. senator and a prominent Reconstruction-era political and religious leader.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Evelyn F. Gregory Target entity description: Evelyn F. Gregory was the taxpayer whose corporate reorganization scheme led to the landmark U.S. Supreme Court tax law case Helvering v. Gregory.
-
A.
Fredricka G. Ross
Fredricka G. Ross is a songwriter best known for co-writing the lyrics to Alicia Keys’ hit ballad “Empire State of Mind (Part II) Broken Down.”
-
B.
Dorothy E. Davis
Dorothy E. Davis was the lead student plaintiff in the Virginia school desegregation case Davis v. County School Board of Prince Edward County, one of the five cases consolidated into the landmark Supreme Court decision Brown v. Board of Education.
-
C.
Dolores H. Russ
Dolores H. Russ was an American philanthropist and co-namesake of the prestigious Fritz J. and Dolores H. Russ Prize in engineering.
-
D.
Margaret C. Etter
Margaret C. Etter was an influential American chemist and crystallographer known for pioneering work in hydrogen bonding and crystal engineering.
-
E.
Phoebe A. Bass
Phoebe A. Bass was the wife of Hiram Revels, the first African American U.S. senator and a prominent Reconstruction-era political and religious leader.
- F. None of above. chosen
Statements (15)
| Predicate | Object |
|---|---|
| instanceOf |
person
ⓘ
taxpayer ⓘ |
| activeInJurisdiction | United States federal tax system ⓘ |
| associatedWithConcept |
business purpose doctrine in U.S. tax law
ⓘ
substance over form doctrine in U.S. tax law ⓘ |
| countryOfCitizenship | United States of America ⓘ |
| fieldOfWork | federal income tax law (as taxpayer involved in litigation) ⓘ |
| hasLegalCase | Helvering v. Gregory ⓘ |
| hasName | Evelyn F. Gregory self-link ⓘ |
| knownFor | corporate reorganization scheme challenged by the U.S. government ⓘ |
| legalSignificance | her transactions led to a landmark U.S. Supreme Court decision on tax avoidance and substance over form ⓘ |
| notableFor | involvement in Helvering v. Gregory ⓘ |
| occupation | taxpayer engaged in corporate reorganization at issue in Helvering v. Gregory ⓘ |
| partyTo | Helvering v. Gregory ⓘ |
| roleInCase | taxpayer in Helvering v. Gregory ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Evelyn F. Gregory Description of subject: Evelyn F. Gregory was the taxpayer whose corporate reorganization scheme led to the landmark U.S. Supreme Court tax law case Helvering v. Gregory.
Referenced by (3)
Full triples — surface form annotated when it differs from this entity's canonical label.
Gregory caused a new corporation to be formed, transferred appreciated stock to it, then liquidated it to obtain the stock at capital gains rates.
→
respondent
→
Evelyn F. Gregory
ⓘ
subject surface form:
Helvering v. Gregory