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Hr* SU louse $ April 2, 1953 light® and the reclamation, drainage and irrigation of land were dearly public• Although X believe that th® majority opinion wrltt®*i by Judge Hand 1® sound, the feet remain® that Circuit Judge Frank wrot® a very vigorous dissent in which h« took th® position that the Fort Authority was engaged in activities ordinarily undertaken by privately owned corporations and was not exercising th® sovereign powers of the state• He mad® a distinction between governmental function® and pro* prietary functions and would have bad the Court hold that th® eas® did not fall within the exemption provisions of the Code or the regulations thereunder* A companion case decided the same day was tbs case of Commissioner of Internal levenue v. n r..darreis, ass®, «Wrhti:t e'«<si .Estate. 144 lug the same question with reference to interest upon bonds issued by the l^ri-Borough Bridge Authority, in which tha majority of the Court came to th© same conclusion and Judge Frank dissented* The question involved in the above mentioned cases eas not be considered to be conclusively settled because the Su* pram® Court merely denied certiorari and did not decide the question on the merits* furthermore, there is greater un* csrtainty with respect to the meaning of Section 23{q){l) than there is with respect to Section 22(b)(4)(A) of the Code because in addition to presenting the problem of what is a political subdivision, Section ifClKl) presents ths problem of whether a contribution to such a political sub* division is "for exclusively public purposes"• There have been a number of other decisions coiastru* lug Section 22(b)(4)(A) of the Code, but they do not throw much light on the problem before us became* they deal pri* msrily with the question of whether certain instruments are "obligations" of a state or its subdivision within the mean* lag of the Code provisions• These cases are collected in an annotation in 121 A,L*t*., page 1276* The only other federal csss which X find interpreting the meaning of "political subdivision" when used in a Federal statute is the case of