Automobile Club of Mich. v. Commissioner

In 1945, the Commissioner of Internal Revenue revoked his 1984 and 1938 rulings exempting the petitioner from federal income taxes, and retroactively applied the revocation to 1943 and 1944. The Commissioner also determined that prepaid membership dues received by the petitioner should be taken into income in the year received, rejecting the petitioner’s method of reporting as income only that part of the dues as was recorded on petitioner’s books as earned in the tax year. The Tax Court sustained the Commissioner’s determinations,1 and *182the Court of Appeals for the Sixth Circuit affirmed.2…