Uptown Club of Manhattan, Inc. v. United States

The issue is whether the plaintiff is a social club or organization within the meaning of Section 17101 of the Internal Revenue Code, as amended.

Pursuant to a ruling of the Collector of Internal Revenue that the plaintiff is a social club, taxes were collected from the members on dues and initiation fees paid by the members to the club from February 1943 to September 30,1947. These taxes were then paid by the club to the defendant. On behalf of the members who signed powers of attorney this suit for a refund has been filed.

The facts are set out in the findings.

The regulations of the Treasury…