In 1928, the petitioner transferred shares from one corporation to another under the guise of a reorganization in order to sell them and pay less income tax. The Commissioner of Internal Revenue believed this was not a legal reorganization and wanted to tax the petitioner as if she had received a dividend. The Board of Tax Appeals disagreed, but the circuit court upheld the commissioner's decision. The Supreme Court granted certiorari and analyzed whether the transfer met the requirements of a statutory reorganization.

Gregory v. Helvering (1935)
Supreme Court of the United States
293 U.S. 465, 79 L. Ed. 596, 55 S. Ct. 266, 1935 U.S. LEXIS 4, SCDB 1934-144

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