Rockefeller Center Luncheon Club, Inc. v. Johnson

BICKS, District Judge.

Plaintiff sues to recover the dues taxes collected from, and paid by it on behalf of, its members for the period March 1943 to August 1946. 1

The decision of this case turns upon the answer to the question: Was the Rockefeller Center Luncheon Club, Inc., a social club or organization within the meaning of Section 1710 of the Internal Revenue Code, 26 U.S.C.A. § 1710, during the period in respect of which the dues taxes were paid?

Section 1710 of the Internal Revenue Code imposes “a tax equivalent to 11 per centum of any amount paid as dues or membership fees to any social…