Sappington v. Commissioner
United States Board of Tax Appeals
Petitioner, an attorney, was employed by University of Maryland as a part-time instructor in its law school. Held, the law school is an integral part of the University, which is a state institution, in the maintenance and operation of which the state is engaged in an essential function of government.
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Petitioner, an attorney, was employed by University of Maryland as a part-time instructor in its law school. Held, the law school is an integral part of the University, which is a state institution, in the maintenance and operation of which the state is engaged in an essential function of government. Held, further, petitioner is an employee of the state, engaged in carrying out an essential governmental function and the compensation paid him by the state for such services is exempt from Federal taxation.
1Opinion of the Court
*1389OPINION.
Goodeioh :
The compensation received by petitioner in 1928 for his services as a part-time instructor in the Law School of the University of Maryland must be included in his gross income for purposes of taxation under the provisions of section 22 of the Revenue Act of 1928 unless while rendering such services he was an officer or employee of the State of Maryland, or a political subdivision thereof, *1390engaged as an instrumentality or agent of the state in administering or executing an essential governmental function of the state; or, if an independent contractor, unless it further…
2Cases cited36 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Burnet v. Coronado Oil & Gas Co.Supreme Court of the United States · 1932
- City of Trenton v. New JerseySupreme Court of the United States · 1923
- Hill v. City of BostonMassachusetts Supreme Judicial Court · 1877
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3Cited by8 opinions
- Wanless Iron Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- REID v. COMMISSIONERUnited States Board of Tax Appeals · 1933
- Bay v. CommissionerUnited States Board of Tax Appeals · 1933
- Modjeski v. CommissionerUnited States Board of Tax Appeals · 1933
- Goodale v. CommissionerUnited States Board of Tax Appeals · 1936
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