Helvering Vs Gregory Case Study

Helvering v. Gregory Summary

Issue

Commissioner Helvering of the Internal Revenue, the plaintiff, petitioned the United States Court of Appeals to review the decision of the Board of Tax Appeals to remove the tax deficiency associated with a transaction affecting the income taxes of the defendant, Evelyn Gregory.
Facts

The Taxpayer, Evelyn Gregory, owned all the shares in United Mortgage Company. United Mortgage owned shares in Monitor Securities Corporation. The taxpayer created Averill Corporation and transferred the shares of Monitor Securities Corporation to Averill Corporation. No other business was ever conducted by the new corporation. The company was dissolved after the transfer and the shares of Monitor Corporation were distributed