Legal Opinion

Bay v. Commissioner

United States Board of Tax Appeals

Decided August 18, 1933No. Docket No. 66014PublishedCited by 2 opinions

1. The Industrial Accident Commission of Maryland is a governmental instrumentality. 2. Petitioner was an employee of the commission in 1929 and the compensation received by him is exempt from Federal income tax.

1Opinion of the Court

*1171OPINION.

Goodrich:

Again we must determine the relationship between a taxpayer and his state government that we may decide whether the compensation paid him for his services by the state may be subjected to the Federal income tax. Petitioner contends that he was either an officer or an employee of the State of Maryland, rendering services to one of its instrumentalities engaged in the discharge of an essential function of government and, consequently, his salary may not be levied upon by the United States. Fox Film Corp. v. Doyal, 286 U.S. 126; art. 648, Regulations 74. The record discloses…

2Cases cited7 opinions

  1. Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
  2. Singer Manufacturing Co. v. RahnSupreme Court of the United States · 1889
  3. Solvuca v. Ryan & Reilly Co.Court of Appeals of Maryland · 1917
  4. Truitt v. CollinsCourt of Appeals of Maryland · 1914
  5. Sappington v. CommissionerUnited States Board of Tax Appeals · 1932

2 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Meigs v. United StatesCourt of Appeals for the First Circuit · 1940
  2. Bay v. CommissionerUnited States Board of Tax Appeals · 1933

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