United States v. Fort Worth Club of Fort Worth, Texas

The Court has carefully considered all of the contentions raised in the petition for rehearing and its supporting brief.

We wish to clarify a matter that was, perhaps, ambiguous in our original opinion: In reversing the decision of the district court, we held only that the Fort Worth Club, because of its substantial and recurrent outside business income, is not entitled to exemption from income tax as a social club under section 501(c) (7) of the Internal Revenue Code of 1954. We did not hold, and we do not mean to imply, that the refund claimed by the taxpayer is, or is not, due. If the Fort…