Affiliated Government Employees' Distributing Co. v. Commissioner

OPINION.

Eaum, Judge:

Petitioner is a nonstock, membership corporation which during the taxable years in issue operated three department stores in the San Francisco Bay area. Only petitioner’s members and their guests were allowed to shop at these stores, which sold a broad line of goods and services purportedly at reduced prices. Membership in petitioner was not open to the public; it was restricted to active and retired government employees (Federal, State, and municipal) and, beginning in the second taxable year 'before us, veterans and widows of government employees. Memberships were for…