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 where 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 where the economic substance varies from its legal form.