CONSOER, OLDER & QUINLAN v. COMMISSIONER OF INT. REV.

No. 5578.

85 F.2d 461 (1936)

CONSOER, OLDER & QUINLAN, Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

June 12, 1936.


Attorney(s) appearing for the Case

Charles D. Hamel, John Enrietto, and C. F. Rothenburg, all of Washington, D. C. (T. A. Kolb, of Chicago, Ill., and Hamel, Park & Saunders, of Washington, D. C., of counsel), for petitioner.

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and John MacC. Hudson, Sp. Assts. to Atty. Gen., for respondent.

Before EVANS and ALSCHULER, Circuit Judges, and LINDLEY, District Judge.


EVANS, Circuit Judge.

This appeal involves the taxability of compensation received for services rendered to municipalities by an engineering corporation, reporting on the accrual basis, which compensation was in the form of vouchers payable out of the first installment of special assessments when collected. The 1926 taxes are $20,099.94, and the 1927 taxes are $20,227.51.

Petitioner contends: (I) This income is exempt because it is an instrumentality of the...

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