From our private database of 26,900+ case briefs...
Gregory v. Helvering
United States Supreme Court
293 U.S. 465 (1935)
Ms. Gregory (plaintiff) owned all the stock of the United Mortgage Corporation (United) and was entitled to receive dividends from United. Among its assets, United owned 1,000 shares of the Monitor Securities Corporation (Monitor). To avoid the ordinary tax treatment of dividend payments received from United, Gregory facilitated a corporate reorganization of United. As a result of this reorganization, United transferred the Monitor shares to Gregory instead of making dividend payments. Gregory fully complied with the technical statutory requirements for a corporate reorganization. Because the transfer of a corporation’s stock to its shareholders during a reorganization constituted capital gain, Gregory treated United’s transfer of Monitor stock to her as capital gain on her federal tax return. The federal tax commissioner (commissioner) (defendant) determined a deficiency in Gregory’s taxes. Gregory petitioned the Board of Tax Appeals (Board) for review, and the Board ruled for Gregory. The United States Court of Appeals for the Second Circuit reversed in favor of the commissioner. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Sutherland, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 541,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 541,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 26,900 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.