Legal Opinion

Ridgway v. Commissioner

United States Board of Tax Appeals

Decided December 3, 1936No. Docket No. 77666Published

1. Petitioner, employed by the Board of Transportation of New York City as its chief engineer, was engaged principally in planning and supervising the construction of the subway system of the city.

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1. Petitioner, employed by the Board of Transportation of New York City as its chief engineer, was engaged principally in planning and supervising the construction of the subway system of the city. Held that the activities of the board were proprietary, rather than governmental and that the compensation received by the petitioner was not exempt from the Federal income tax. 2. Petitioner was paid for services rendered to a board of the city of Chicago under a contract specifying, in a general way, his duties as a consulting engineer and his compensation. Held that he was an independent…

1Opinion of the Court

ROBERT RIDGWAY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ridgway v. Commissioner

Docket No. 77666.

United States Board of Tax Appeals

35 B.T.A. 122; 1936 BTA LEXIS 560;

December 3, 1936, Promulgated

1. Petitioner, employed by the Board of Transportation of New York City as its chief engineer, was engaged principally in planning and supervising the construction of the subway system of the city. Held that the activities of the board were proprietary, rather than governmental and that the compensation received by the petitioner was not exempt from the Federal income tax.

2.…

2Cases cited19 opinions

  1. M'culloch v. State of MarylandSupreme Court of the United States · 1819
  2. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  3. Pollock v. Farmers' Loan & Trust Co.Supreme Court of the United States · 1895
  4. Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
  5. South Carolina v. United StatesSupreme Court of the United States · 1905

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