Halsey v. Commissioner
United States Board of Tax Appeals
A municipal engineer who receives from the municipality a small annual retainer and also fees amounting to five percent of the contract cost of construction projects, held not immune from Federal income tax in respect of such percentage amount, since from the evidence it can not be determined whether the projects or the petitioner's functions and services in respect thereof were governmental in character.
1Opinion of the Court
EDMUND R. HALSEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Halsey v. Commissioner
Docket Nos. 51246, 56310, 61217, 67231.
United States Board of Tax Appeals
28 B.T.A. 1213; 1933 BTA LEXIS 1036;
August 22, 1933, Promulgated
A municipal engineer who receives from the municipality a small annual retainer and also fees amounting to five percent of the contract cost of construction projects, held not immune from Federal income tax in respect of such percentage amount, since from the evidence it can not be determined whether the projects or the petitioner's functions and services in…
2Cases cited1 opinion
- Halsey v. CommissionerUnited States Board of Tax Appeals · 1933