Helvering v. Gregory
E62216
Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions must have a genuine business purpose beyond tax avoidance to be respected for tax purposes.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Helvering v. Gregory canonical | 5 |
| Helvering v. Gregory, 293 U.S. 465 (1935) | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T486099 — 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: Helvering v. Gregory Context triple: [Guy T. Helvering, notableWork, Helvering v. Gregory]
-
A.
Helvering v. Clifford
Helvering v. Clifford is a landmark 1940 U.S. Supreme Court tax law case that clarified when income from a trust should be attributed to the grantor for federal income tax purposes.
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B.
Helvering v. Horst
Helvering v. Horst is a 1940 U.S. Supreme Court case that established key principles of the assignment of income doctrine in federal tax law.
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C.
Helvering v. Davis
Helvering v. Davis is a 1937 U.S. Supreme Court case that upheld the constitutionality of the Social Security Act and broadly affirmed federal power to tax and spend for the general welfare.
-
D.
Helvering v. Bruun
Helvering v. Bruun is a 1940 U.S. Supreme Court case that addressed whether a landlord realizes taxable income when repossessing property improved by a tenant.
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E.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
- 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: Helvering v. Gregory Target entity description: Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions must have a genuine business purpose beyond tax avoidance to be respected for tax purposes.
-
A.
Helvering v. Clifford
Helvering v. Clifford is a landmark 1940 U.S. Supreme Court tax law case that clarified when income from a trust should be attributed to the grantor for federal income tax purposes.
-
B.
Helvering v. Horst
Helvering v. Horst is a 1940 U.S. Supreme Court case that established key principles of the assignment of income doctrine in federal tax law.
-
C.
Helvering v. Davis
Helvering v. Davis is a 1937 U.S. Supreme Court case that upheld the constitutionality of the Social Security Act and broadly affirmed federal power to tax and spend for the general welfare.
-
D.
Helvering v. Bruun
Helvering v. Bruun is a 1940 U.S. Supreme Court case that addressed whether a landlord realizes taxable income when repossessing property improved by a tenant.
-
E.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
- F. None of above. chosen
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
landmark case ⓘ tax law case ⓘ |
| arguedDate | 1934-11-14 ⓘ |
| category |
United States Supreme Court cases in 1935
ⓘ
United States corporate taxation case law ⓘ United States taxation and revenue case law ⓘ |
| citation | 293 U.S. 465 ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1935-01-07 ⓘ |
| decisionType | unanimous decision ⓘ |
| factualBackground | Gregory caused a new corporation to be formed, transferred appreciated stock to it, then liquidated it to obtain the stock at capital gains rates. ⓘ |
| fullName |
Helvering v. Gregory
self-linksurface differs
ⓘ
surface form:
Helvering v. Gregory, 293 U.S. 465 (1935)
|
| holding |
A transaction must have a genuine business purpose beyond tax avoidance to be respected for tax purposes.
ⓘ
A transaction that complies with the literal language of the statute may still be disregarded if it is a mere device to avoid tax. ⓘ |
| impact |
Became a foundational case for the business purpose requirement in U.S. tax law.
ⓘ
Frequently cited in tax planning and tax litigation involving avoidance schemes. ⓘ Influenced later development of the economic substance doctrine. ⓘ |
| issue | Whether a purported corporate reorganization undertaken solely to avoid tax qualified as a reorganization under the Revenue Act. ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| keyConcept |
economic substance
ⓘ
sham transaction ⓘ tax-motivated reorganization ⓘ |
| languageOfOpinion | English ⓘ |
| legalArea |
corporate reorganization
ⓘ
federal income tax law ⓘ tax avoidance ⓘ |
| lowerCourtJudge | Learned Hand ⓘ |
| opinionBy | Justice George Sutherland ⓘ |
| originatingJurisdiction | United States Court of Appeals for the Second Circuit ⓘ |
| partyRole |
Gregory was a taxpayer and shareholder.
ⓘ
Guy T. Helvering ⓘ
surface form:
Helvering was the Commissioner of Internal Revenue.
|
| petitioner |
Guy T. Helvering
ⓘ
surface form:
Guy T. Helvering, Commissioner of Internal Revenue
|
| precedentFor | cases evaluating whether transactions have a legitimate non-tax business purpose. ⓘ |
| principleEstablished |
business purpose doctrine
ⓘ
substance over form doctrine in tax law ⓘ |
| reasoning |
The Court looked to the substance of the transaction rather than its formal compliance with statutory language.
ⓘ
The reorganization provisions were intended to apply only to transactions undertaken for reasons germane to the business. ⓘ |
| relatedDoctrine |
economic substance doctrine
ⓘ
step transaction doctrine ⓘ substance over form ⓘ |
| reporter | United States Reports ⓘ |
| respondent | Evelyn F. Gregory ⓘ |
| result | Judgment of the Second Circuit affirmed. ⓘ |
| statuteInterpreted | Revenue Act of 1928 ⓘ |
| volume | 293 ⓘ |
| year | 1935 ⓘ |
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: Helvering v. Gregory Description of subject: Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions must have a genuine business purpose beyond tax avoidance to be respected for tax purposes.
Referenced by (6)
Full triples — surface form annotated when it differs from this entity's canonical label.
this entity surface form:
Helvering v. Gregory, 293 U.S. 465 (1935)
subject surface form:
Gregory