REID v. COMMISSIONER
United States Board of Tax Appeals
The city architect of San Francisco who, in addition to his own work for the city, conducted a private practice as an architect, and who was compensated by the city upon the basis of a percentage of the cost of construction projects in respect of which his services were performed, held not immune from Federal income tax upon such compensation.
1Opinion of the Court
*1220OPINION.
Sternhagen :
The respondent added to petitioner’s income the compensation received for his architectural services to the city of San Francisco during the years 1924 to 1928, inclusive. Article 88 of Regulations 62, 65, and 69, and article 643 of Regulations 74, all provide in part that:
Compensation paid to its officers and employees by a State or political subdivision thereof * * * is not taxable.
*1221Kegulations 69 and 74 restrict the article’s application to compensation paid for services rendered in connection with the exercise of an essential governmental function. The 1926 Act, section…
2Cases cited21 opinions
- M'culloch v. State of MarylandSupreme Court of the United States · 1819
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- United States v. HartwellSupreme Court of the United States · 1868
- South Carolina v. United StatesSupreme Court of the United States · 1905
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3Cited by3 opinions
- Lynch v. CommissionerUnited States Board of Tax Appeals · 1934
- Hall v. CommissionerUnited States Board of Tax Appeals · 1936
- REID v. COMMISSIONERUnited States Board of Tax Appeals · 1933