Simpson v. Commissioner

*558OPINION.

Smith :

The petitioners contend that:

* * * E. A. Simpson, was an employé, or an officer, of tbe City of Amarillo; that the compensation paid to him and his law partners was paid by the City of Amarillo in the exercise of essential governmental functions.

There is no provision in the Revenue Act of 1928 comparable to section 1211 of the Revenue Act of 1926, which exempted from the tax imposed by the Revenue Act of 1924 and prior revenue acts the compensation of an officer or employee of a state or political subdivision thereof. See Leland Powers, Executor, 26 B.T.A. 1381.

The law firm of…