Union Club of Pittsburgh v. Heiner

I am constrained to dissent from the opinion of the majority in the case at bar. My reasons for doing so are as follows:

The learned District Judge found as a fact that the appellant “ * * * was a social club as defined by the Revenue Jaws of the United States.” In my opinion this finding was correct and is supported by ample evidence.

Briefly enumerated that evidence is as follows: The appellant was incorporated in 1903, and the incorporators asserted in their petition to the judges of the Court of Common Pleas of Allegheny County, Pennsylvania, that they “ * * * associated themselves together…