Quinnipiack Club v. United States

This is a suit for the recovery of $16,599.-01, taxes on initiation fees and dues, alleged to have been erroneously assessed and collected by the Commissioner of Internal Revenue, on the ground that the plaintiff was not a social, athletic, or sporting club within the meaning of section 501 of the Revenue Act of 1926 (26 USCA § 872 note) and section 413 of the Revenue Act of 1928 (26 USCA § 872).

The court, upon the report of a commissioner, makes the following special findings of fact:

1. The plaintiff was organized on March 29, 1871, and incorporated as the Quinnipiaek Club of New Haven under…