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Las Vegas, Nev; March 27th, 19: Iff Mr. E.E. Bennett: I hasten to reply to your letter of March 25th, 1952, relative to the disposal of the Water Company to the Las Vegas Valley Water District on a sale or donation basis. Las Vegas Valley Water District exercises part of the sovereign powers of the State of Nevada and should be classified as a political subdivision within the mean­ing of the internal revenue code sections. \ Section 19 of the Las Vegas Valley Water District Abt, Section $254*19 NCL 1943-1949 Supp., as amended by the 1951 Legislature, Nevada Stats, 1951, Chapter 3Q7, page 4^4, grants to the Water District complete authority for the doing of the things auth­orized 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 authorized 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. declares that the furnishing of water by the district is a public purpose. "Since the water district, for the creation of which provision is herein made, is created for the purpose of supplying its inhabitants with water as a public and municipal function, all pro­perty of the district shall be exempt from taxes by the State of Nevada and the political subdivision^thereof, and the bonds issued by the district and the income therefrom shall also be exempt from taxation in this state Unfortunately, the Las Vegas Valley Water District Act does not expressly declare that the dis­trict created thereunder is a municipal corporation as is the case in the Nevada Housing Authority Law, Chapter 253, Nevada Statutes 1947, Sections 5470.01-5470.25 NCL 1943-1949, Supp. I agree with your offhand opinion that the Furthermore, this same section expressly