United States v. Brad B. Bailey

HUTCHESON, Circuit Judge.

This appeal by the United States attacks the judgment of the district court which granted refund for taxes assessed on amounts claimed to be initiation fees and further held that the collection of the tax is barred by the statute of limitations. We sustain the government on both points, and reverse.

The Downtown Club of Meridian is a Mississippi corporation organized on January 13, 1958. There are six classes of membership in the Club. 1 The Charter-Resident class is restricted to holders of stock in the corporation. 2 Taxpayer qualified for membership in this class on…