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f V Mr* ¥. S. Rouse 4. April 2, Iffi speet to tax liability under prospective transaction®* The desirability of obtaining such a closing agreement is en­hanced by the fact that in the two cases which I have al­ready mentioned construing Section 22(b)(4)(A) with respect to the meaning of "political subdivision" the Government took a position contrary to previous rulings of the Commis­sioner with respect to the very Governmental agencies which were there concerned* CogBsiaalonar v. ghybergfa lefcats* 144 Fed* 2d 99# t Cossmigslonsr ' V. ~Whit e*a ¥a t ate. 144 '^eS. 2d 1019. Hie las Vegas Valley water District was organised rai­der the authority of an act of the Kevada Legislature ap­proved March 27, 1947, as amended by the Statutes of 1949, page 20#, and Statutes of 1951, page 4#4* Under this Act the District has perpetual succession power to sue and he sued| to acquire property by purchase or under the right of eminent domain, to store, conserve, appropriate, import and distribute water, to prevent contamination, pollution of surface or sub-surface water; to borrow money end issue bonds, to construct or acquire water systems, to distrib­ute water for domestic, industrial or irrigation use and to cause taxes to be levied to pay obligations of the Dis­trict during its organisational stage and for the purpose of supplementing other revenues of the District available for the payment of principal and interest on bond issues created by the District* Among the powers of the District are those which have always been considered as essentially sovereign powers, such as the right to exercise police power and to levy taxes* Other powers which are govern­mental powers, although sometimes exercised by private corporations, are the powers of eminent domain, the power to borrow and spend money for the purposes ©f the District, etc* Section 19 of the las Vegas Talley voter District Act, grants to the Water District complete authority for the do­ing of the things authorised to be done* "The provisions of no other law, either general or local, except as provid­ed in this Act, shall apply to doing of the things herein authorised to be done, and no board, agency, bureau or of­ficial other than the governing body of the district shall have any authority or Jurisdiction over the doing of any of the acts, etc* * * * ** Therefore the Water District certainly exercises part of the sovereign powers of the State of Nevada*