upr000160 194

Mr. W. R. Rouse April 2, 1952 Bfiafik v. Little.Elver 239 U.&. *54, &Q t . ©of* D, riani nia«g*ei eDhitsot#r ilcut-. pry® Court hold & drainage district forced under Missouri laws to be a political subdi­vision of the state for the purpose of per­forming prescribed functions of government. M v, Puerto Rico Communication Author­ed. Wupp, 34, feoiding the Puerto'Rico Communications Authority, which operated tele­phone and telegraph service ©a the island, to be a political subdivision of the Insular Gov­ernment and exempt from application of the Fair Labor Standards Act. App. jI2|dM)* L7,40p,p Hhloflld inv.g tChoautn tay woaft eOrr adnigset. ri3c0t Ccarl.e ­ated under the laws of California was not a mun­icipal corporation within the meaning of certain constitutional provisions, but was a public agen­cy exercising governmental functions, such as power of taxation and eminent domain. We should not overlook the fact, however, that there are many decisions holding that public districts of the character of the Las Vegas Water District are not polit­ical subdivisions of the state within the meaning of var­ious typos of statutes. An illustrative esse is that of Maricopa County water Conservation District (Aris.J, 40 fee • (2d) 94, hold that the water district they involved was not a political subdivision ©f the state, although it exercised the taxing power.because it® pur­poses were primarily business rather than governmental. In view of the conflict in the decisions there ex­ists the possibility that the Commissioner of Internal Revenue might take the position that the Las Vegas Water District is not a political subdivision within the mean­ing of the provisions of the Internal Revenue Code and the regulations thereunder above mentioned. Such was tbs position taken by the Commissioner in the case of Commis­sioner v. Shaibsrg* a Estate, 144 Fed. 2d 998, certiorari " denied, 89 L* sd. 031, involving a deficiency in income