Legal Opinion

Affiliated Government Employees' Distributing Co. v. Commissioner

United States Tax Court

Decided February 12, 1962No. Docket No. 84190Published

Petitioner, a California nonstock membership corporation, operates a group of department stores in the San Francisco Bay area for the exclusive use of its members and their guests.

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Petitioner, a California nonstock membership corporation, operates a group of department stores in the San Francisco Bay area for the exclusive use of its members and their guests. Membership is not open to the public but is restricted to active and retired government employees and widows of such government employees for a fee of $ 2 and to veterans for a fee of $ 3. Membership is for life, terminates automatically upon death, is nontransferable and nonassessable, and is represented by a wallet-sized passcard which is used to identify the holder for admittance to petitioner's stores. Held…

1Opinion of the Court

Affiliated Government Employees' Distributing Company, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Affiliated Government Employees' Distributing Co. v. Commissioner

Docket No. 84190

United States Tax Court

37 T.C. 909; 1962 U.S. Tax Ct. LEXIS 194;

February 12, 1962, Filed

Decision will be entered for the respondent.

Petitioner, a California nonstock membership corporation, operates a group of department stores in the San Francisco Bay area for the exclusive use of its members and their guests. Membership is not open to the public but is restricted to active and retired…

2Cases cited16 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  4. Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
  5. Automobile Club of Michigan v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956

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