United States v. Fort Worth Club of Fort Worth, Texas

WISDOM, Circuit Judge.

We face a narrow issue: was the taxpayer, the Forth Worth Club, during its fiscal year ending April 30, 1960, “organized and operated exclusively for pleasure, recreation and other non-profitable purposes”, within the meaning of section 501(c) (7) of the Internal Revenue Code of 1954? A strict reading of the statute requires us to hold that the club was not so organized and operated; through a wholly owned subsidiary, the club was in the business of leasing office space to the general public.

The taxpayer is a downtown men’s club in Fort Worth, Texas. By rulings dated…