Commissioner of Internal Revenue v. Schnackenberg

LINDLEY, District Judge.

The question presented by these two petitions to review decisions of the Board of Tax Appeals is whether the salary and compensation of the taxpayer, as general attorney for the South Park commissioners of Chicago, is a part of his taxable income. The answer depends upon, (1), whether thé park commissioners, as a political subdivision of the state of Illinois, are engaged in the exercise of governmental functions; (2), whether the taxpayer is an officer of a subdivision of the state, or an independent contractor, and (3), whether there is any legal distinction between…