Legal Opinion

Jeffries v. Commissioner

United States Board of Tax Appeals

Decided April 22, 1938No. Docket No. 81968Published

The South Florida Conservancy District on the facts presented was an instrumentality of the State of Florida, engaged in the exercise of functions essentially governmental in character. Held, that an amount received from the district as salary by an officer thereof was exempt from the Federal income tax.

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The South Florida Conservancy District on the facts presented was an instrumentality of the State of Florida, engaged in the exercise of functions essentially governmental in character. Held, that an amount received from the district as salary by an officer thereof was exempt from the Federal income tax. Brush v. Commissioner,300 U.S. 352; Collector v. Day,11 Wall. 113; Commissioner v. Harlan, 80 Fed.(2d) 660; Helvering v. Mountain Producers Corporation,303 U.S. 376, compared and distinguished.

1Opinion of the Court

LILLIAN M. JEFFRIES, ADMINISTRATRIX, ESTATE OF JAMES B. JEFFRIES, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Jeffries v. Commissioner

Docket No. 81968.

United States Board of Tax Appeals

37 B.T.A. 742; 1938 BTA LEXIS 991;

April 22, 1938, Promulgated

The South Florida Conservancy District on the facts presented was an instrumentality of the State of Florida, engaged in the exercise of functions essentially governmental in character. Held, that an amount received from the district as salary by an officer thereof was exempt from the Federal income tax. Brush v.…

2Cases cited14 opinions

  1. Collector v. DaySupreme Court of the United States · 1871
  2. Houck v. Little River Drainage DistrictSupreme Court of the United States · 1915
  3. Gillespie v. OklahomaSupreme Court of the United States · 1922
  4. Ohio v. HelveringSupreme Court of the United States · 1934
  5. Helvering v. Mountain Producers Corp.Supreme Court of the United States · 1938

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