White v. Winchester Country Club

We must decide whether members’ payments to the Winchester Country Club for certain “privileges” constituted “dues or membership fees” subject to the tax imposed by § 501 of the Revenue Act of 1926, 44 Stat. 9, 92, as amended by § 413 of the Revenue Act of 1928, 45 Stat. 791, 864, on amounts 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 $25 per year.”

Since 1929 and during the period here in question the Club’s by-laws provided for “Annual Dues” of $50, which entitled a member…