Gregory caused a new corporation to be formed, transferred appreciated stock to it, then liquidated it to obtain the stock at capital gains rates.
E302256
Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions lacking economic substance beyond tax avoidance can be disregarded for tax purposes.
All labels observed (1)
How this entity was disambiguated
This entity first appeared as the object of triple T2830216 — 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.
Target entity: Gregory caused a new corporation to be formed, transferred appreciated stock to it, then liquidated it to obtain the stock at capital gains rates. Context triple: [Helvering v. Gregory, 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.]
-
A.
Incorporation doctrine
The Incorporation doctrine is a constitutional principle through which most protections in the U.S. Bill of Rights have been made enforceable against state governments via the Fourteenth Amendment.
-
B.
Subchapter S
Subchapter S is the section of U.S. tax law that governs S corporations, allowing certain closely held corporations to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes.
-
C.
Tax Division
The Tax Division is a component of the U.S. Department of Justice responsible for enforcing federal tax laws and handling civil and criminal tax litigation on behalf of the United States.
-
D.
2019 Statement on the Purpose of a Corporation
The 2019 Statement on the Purpose of a Corporation is a landmark declaration by major U.S. CEOs redefining corporate purpose to prioritize all stakeholders—employees, customers, suppliers, and communities—rather than focusing solely on shareholder value.
-
E.
Rule 144
Rule 144 is a U.S. Securities and Exchange Commission regulation that provides a safe harbor for the public resale of restricted and control securities if specific holding period, volume, and disclosure conditions are met.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
Target entity: Gregory caused a new corporation to be formed, transferred appreciated stock to it, then liquidated it to obtain the stock at capital gains rates. Target entity description: Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions lacking economic substance beyond tax avoidance can be disregarded for tax purposes.
-
A.
Incorporation doctrine
The Incorporation doctrine is a constitutional principle through which most protections in the U.S. Bill of Rights have been made enforceable against state governments via the Fourteenth Amendment.
-
B.
Subchapter S
Subchapter S is the section of U.S. tax law that governs S corporations, allowing certain closely held corporations to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes.
-
C.
Tax Division
The Tax Division is a component of the U.S. Department of Justice responsible for enforcing federal tax laws and handling civil and criminal tax litigation on behalf of the United States.
-
D.
2019 Statement on the Purpose of a Corporation
The 2019 Statement on the Purpose of a Corporation is a landmark declaration by major U.S. CEOs redefining corporate purpose to prioritize all stakeholders—employees, customers, suppliers, and communities—rather than focusing solely on shareholder value.
-
E.
Rule 144
Rule 144 is a U.S. Securities and Exchange Commission regulation that provides a safe harbor for the public resale of restricted and control securities if specific holding period, volume, and disclosure conditions are met.
- F. None of above. chosen
Statements (41)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
landmark case ⓘ tax law case ⓘ |
| appliesTo | federal income tax transactions lacking economic substance ⓘ |
| areaOfLaw | federal income tax law ⓘ |
| citation | 293 U.S. 465 ⓘ |
| citedFor |
the proposition that sham transactions may be ignored for tax purposes
ⓘ
the requirement of a bona fide business purpose in tax-free reorganizations ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1935 ⓘ |
| establishedPrinciple |
business purpose doctrine in tax law
ⓘ
economic substance doctrine in tax law ⓘ substance over form doctrine in tax law ⓘ |
| holding | a transaction with no business purpose or economic substance beyond tax avoidance may be disregarded for tax purposes ⓘ |
| impact |
became a foundational precedent for the economic substance doctrine
ⓘ
frequently cited in U.S. tax litigation ⓘ influenced later codification of economic substance in the Internal Revenue Code ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| keyFactPattern |
taxpayer caused a new corporation to be formed
ⓘ
taxpayer received the appreciated stock upon liquidation ⓘ taxpayer transferred appreciated stock to the new corporation ⓘ the new corporation was then liquidated ⓘ |
| languageOfOpinion | English ⓘ |
| legalIssue | whether a corporate reorganization lacking business purpose qualifies for tax-free treatment ⓘ |
| opinionBy | Justice George Sutherland ⓘ |
| petitioner |
Guy T. Helvering
ⓘ
surface form:
Guy T. Helvering, Commissioner of Internal Revenue
|
| reasoning |
a transaction that is a mere device to avoid tax does not qualify as a statutory reorganization
ⓘ
the reorganization provisions were intended to apply only to transactions undertaken for reasons germane to the business ⓘ |
| relatedConcept |
Internal Revenue Code
ⓘ
surface form:
Internal Revenue Code reorganization provisions
capital gains ⓘ corporate reorganization ⓘ dividends ⓘ tax avoidance ⓘ tax evasion ⓘ |
| respondent | Evelyn F. Gregory ⓘ |
| standsFor |
tax consequences are determined by the substance of a transaction, not merely its form
ⓘ
taxpayers may arrange their affairs to minimize tax, but must respect the requirements of the tax statute ⓘ |
| taxObjective | to obtain capital gains treatment instead of ordinary income or dividend treatment ⓘ |
| timePeriod |
Great Depression
ⓘ
surface form:
Great Depression era
|
| unanimousDecision | true ⓘ |
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.
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.
Subject: Gregory caused a new corporation to be formed, transferred appreciated stock to it, then liquidated it to obtain the stock at capital gains rates. Description of subject: Helvering v. Gregory is a landmark 1935 U.S. Supreme Court tax law case that established the principle that transactions lacking economic substance beyond tax avoidance can be disregarded for tax purposes.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.