Arkwright Club of City of New York, Inc. v. United States

WHITAKER, Judge.

The question presented here is whether the members of this club are members of a social club and, therefore, subject to tax on initiation fees and dues paid to the club. The test is whether the social features of the club are a material purpose of its organization and maintenance or whether they are only incidental to a predominant purpose not social, such as religion, the arts, sciences, or business.

In its certificate of incorporation the incorporators stated that the objects for which the club was being formed were “the social and mutual benefit of the members thereof and to…