Gregory v. Helvering
Gregory v. Helvering, 293 U.S. 465 (1935), was a landmark decision by the United States Supreme Court concerned with U.S. income tax law. The case is cited as part of the basis for two legal doctrines: the business purpose doctrine and the doctrine of substance over form. The business purpose doctrine is essentially that if a transaction has no substantial business purpose other than the avoidance or reduction of Federal tax, the tax law will not regard the transaction. The doctrine of substance over form is essentially that for Federal tax purposes, a taxpayer is bound by the economic substance of a transaction if the economic substance varies from its legal form.
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293 U.S. 46569 F.2d 809Alderson v. CommissionerEconomic substanceGregory v. ΗelveringGregory v HelveringHealth Care and Education Reconciliation Act of 2010January 1935List of United States Supreme Court cases by the Hughes CourtList of landmark court decisions in the United StatesStep transaction doctrineSubstance over formTax avoidanceTax evasion in the United StatesTax noncompliance
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Gregory v. Helvering
Gregory v. Helvering, 293 U.S. 465 (1935), was a landmark decision by the United States Supreme Court concerned with U.S. income tax law. The case is cited as part of the basis for two legal doctrines: the business purpose doctrine and the doctrine of substance over form. The business purpose doctrine is essentially that if a transaction has no substantial business purpose other than the avoidance or reduction of Federal tax, the tax law will not regard the transaction. The doctrine of substance over form is essentially that for Federal tax purposes, a taxpayer is bound by the economic substance of a transaction if the economic substance varies from its legal form.
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Gregory v. Helvering, 293 U.S. ...... ce varies from its legal form.
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Gregory v. Helvering,
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Evelyn Gregory v. Guy T. Helvering, Commissioner of Internal Revenue
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For a business reorganization ...... w permits, cannot be doubted."
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unanimous
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Gregory v. Helvering
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Sutherland
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Gregory v. Helvering, 293 U.S. ...... ce varies from its legal form.
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Gregory v. Helvering
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Evelyn Gregory v.Guy T. Helvering, Commissioner of Internal Revenue
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