Wood v. Commissioner
United States Board of Tax Appeals
EXEMPT INCOME - SALARY OF AN EMPLOYEE OF A TEXAS WATER CONTROL AND IMPROVEMENT DISTRICT ORGANIZED UNDER TEXAS STATE LAW NOT EXEMPT FROM TAXATION. - In 1928 petitioner D. G. Wood was an employee of Hidalgo County Water Control and Improvement District No. 6, organized under the laws and Constitution of the State of Texas. Held, such district is a political subdivision of the State of Texas.
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EXEMPT INCOME - SALARY OF AN EMPLOYEE OF A TEXAS WATER CONTROL AND IMPROVEMENT DISTRICT ORGANIZED UNDER TEXAS STATE LAW NOT EXEMPT FROM TAXATION. - In 1928 petitioner D. G. Wood was an employee of Hidalgo County Water Control and Improvement District No. 6, organized under the laws and Constitution of the State of Texas. Held, such district is a political subdivision of the State of Texas. It was not engaged during the taxable year in the performance of essential governmental functions. The salary of petitioner as manager of the district is not exempt from taxation. T. P. Wittschen,25 B.T.A.…
1Opinion of the Court
OPINION.
Black:
For the year 1928 the petitioners, D. G. Wood and wife, reported an income of $7,834, one half by the husband and one half by the wife.
The returns of petitioners did not include as taxable income an item of $6,000 representing salary received for the year by petitioner D. G. Wood as general manager of Hidalgo County Water Control and Improvement District No. 6. The Commissioner has added this $6,000 to income and has determined deficiencies of $47.13 against each of the petitioners.
From this determination the petitioners have brought a joint appeal and allege the following…
2Cases cited3 opinions
- Wittschen v. CommissionerUnited States Board of Tax Appeals · 1931
- Burges v. CommissionerUnited States Board of Tax Appeals · 1929
- Niles v. CommissionerUnited States Board of Tax Appeals · 1930
3Cited by3 opinions
- Jeffries v. CommissionerUnited States Board of Tax Appeals · 1938
- Wait v. CommissionerUnited States Board of Tax Appeals · 1937
- Wood v. CommissionerUnited States Board of Tax Appeals · 1934