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COMMISSIONER OF INTERNAL REVENUE v. SCHNACKENBERG

Nos. 6076, 6077.

90 F.2d 175 (1937)

COMMISSIONER OF INTERNAL REVENUE v. SCHNACKENBERG. SCHNACKENBERG v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

May 25, 1937.

Attorney(s) appearing for the Case

James W. Morris, Asst. Atty. Gen., and Sewall Key, Norman D. Keller, and Howard P. Locke, Sp. Assts. to the Atty. Gen., for Commissioner of Internal Revenue.

Elmer J. Schnackenberg, of Chicago, Ill., pro se.

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

LINDLEY, District Judge.

The question presented by these two petitions to review decisions of the Board of Tax Appeals is whether the salary and compensation of the taxpayer, as general attorney for the South Park commissioners of Chicago, is a part of his taxable income. The answer depends upon, (1), whether the park commissioners, as a political subdivision of the state of Illinois, are engaged in the exercise of governmental functions; (2), whether the taxpayer...

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