Chattanooga Automobile Club v. Commissioner of Internal Revenue. Warren Automobile Club, Inc. v. Commissioner of Internal Revenue

MARTIN, Circuit Judge.

In both these cases, the petitioners seek review and reversal of decisions of the United States Tax Court upholding determinations by the Commissioner of Internal Revenue of deficiencies in income tax and declared value excess-profits tax for their respective fiscal years ending during 1944. Though argued and submitted separately, the controlling issue in each case is the same. We will, therefore, announce decision in both cases in one opinion.

Both the Chattanooga Automobile Club and the Warren Automobile Club, Inc., were incorporated many years ago as nonprofit…