Affiliated Government Employees' Distributing Co. v. Commissioner
United States Tax Court
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
OPINION.
Eaum, Judge:
Petitioner is a nonstock, membership corporation which during the taxable years in issue operated three department stores in the San Francisco Bay area. Only petitioner’s members and their guests were allowed to shop at these stores, which sold a broad line of goods and services purportedly at reduced prices. Membership in petitioner was not open to the public; it was restricted to active and retired government employees (Federal, State, and municipal) and, beginning in the second taxable year 'before us, veterans and widows of government employees. Memberships were for…
2Cases cited15 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
- Automobile Club of Michigan v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
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3Cited by2 opinions
- United Grocers, Ltd. v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Affiliated Government Employees' Distributing Co. v. CommissionerUnited States Tax Court · 1962