She then created Averill Corp and then transferred the 1,000 shares of Monitor to Averill for a capital net gain of $76,007.88. She then treated the transaction as a tax free corporate organization under “a 'reorganization' under section 112(g) of the Revenue Act of 1928, c. 852, 45 Stat. 791, 816, 818, 26 USCA 2112(g), “(Caselaw.findlaw.com) The decision came from the supreme court of “ It is earnestly contended on behalf of the taxpayer that since every element required by the foregoing subdivision (B) is to be found in what was done, a statutory reorganization was effected; and that the motive of the taxpayer thereby to escape payment of a tax will not alter the result [293 U.S. 465, 469] or make unlawful what the statute allows.” (Caselaw.findlaw.com) Even though the individual acted without the counseling of a tax lawyer or accountant, her ambition to scheme in tax sheltering sparked a new interest that would continue