Wanless Iron Co. v. Commissioner

*841OPINION.

McMahon :

The petitioner contends that it and the leases involved herein are governmental instrumentalities or agencies of the State of Minnesota for the development and operation of its school lands, dedicated to the support of its public schools; and that therefore it is immune from Federal taxation.

*842It has been held that in maintaining its public schools a state is exercising a “ function strictly governmental in character.” Burnet v. Coronado Oil & Gas Co., 285 U.S. 123. To the same effect is G. Ridgely Sappington, 25 B.T.A. 1385.

The Supreme Court of the United States has prescribed…