The Downtown Club of Dallas v. United States

JONES, Circuit Judge.

The Commissioner of Internal Revenue ruled that The Downtown Club of Dallas, Texas, was a social club within the meaning of 26 U.S.C.A. (I.R.C.1939) § 1710, which provides:

“There shall be levied, assessed, collected, and paid—

“(1) Dues or membership fees. A tax equivalent to 20 per centum of any amount paid as dues or membership fees to any social, athletic, or sporting club or organization, if the dues or fees of an active resident annual member are in excess of $10 per year.

“(2) Initiation fees. A tax equivalent to 20 per centum of any amount paid as initiation fees to…