ner that minimizes or avoids taxes by any means the @2011 Wolters Kluwer. All rights reserved. 6 of 8 7/28/2011 7:44 AM EFTA00598152 laws allow. Gregory v. Havering( 35-1 USTC ¶9043), 293 U.S. 465, 469 (1935). Courts, however, may disregard the form of a transaction in favor of its substance where there is collu