Sappington v. Commissioner
United States Board of Tax Appeals
Petitioner, an attorney, was employed by University of Maryland as a part-time instructor in its law school. Held, the law school is an integral part of the University, which is a state institution, in the maintenance and operation of which the state is engaged in an essential function of government.
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Petitioner, an attorney, was employed by University of Maryland as a part-time instructor in its law school. Held, the law school is an integral part of the University, which is a state institution, in the maintenance and operation of which the state is engaged in an essential function of government. Held, further, petitioner is an employee of the state, engaged in carrying out an essential governmental function and the compensation paid him by the state for such services is exempt from Federal taxation.
1Opinion of the Court
G. RIDGELY SAPPINGTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Sappington v. Commissioner
Docket No. 51944.
United States Board of Tax Appeals
25 B.T.A. 1385; 1932 BTA LEXIS 1389;
April 30, 1932, Promulgated
Petitioner, an attorney, was employed by University of Maryland as a part-time instructor in its law school. Held, the law school is an integral part of the University, which is a state institution, in the maintenance and operation of which the state is engaged in an essential function of government. Held, further, petitioner is an employee of the state, engaged in carrying…
2Cases cited46 opinions
- Marbury v. MadisonSupreme Court of the United States · 1803
- Pierce v. Society of SistersSupreme Court of the United States · 1925
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Boyd's Lessee v. GravesSupreme Court of the United States · 1819
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
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