Cochran v. Commissioner

McCORD, Circuit Judge.

S. H. Cochran petitions for review of a decision of the Board of Tax Appeals sustaining income tax deficiencies assessed against him for the years 1936 and 1937 in the aggregate sum of $5,982.01.

The question for decision is whether commissions received by the taxpayer in 1936 and 1937 for services as Land Agent for Mobile County, Alabama, are exempt from income tax under the provisions of the Public Salary Tax Act of 1939, 26 U.S.C.A. Int.Rev.Code § 22(a), which extended tax immunity for the years in question to amounts received as “compensation * * * as an officer or…