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ARKWRIGHT CLUB OF CITY OF NEW YORK v. UNITED STATES

No. 50065.

117 F.Supp. 411 (1954)

ARKWRIGHT CLUB OF CITY OF NEW YORK, Inc. v. UNITED STATES.

United States Court of Claims.

January 5, 1954.

Attorney(s) appearing for the Case

John C. Reid, Washington, D. C., for plaintiff. Ivins, Phillips & Barker, Washington, D. C., were on the briefs.

A. Barr Comstock, Washington, D. C., with whom was H. Brian Holland, Asst. Atty. Gen., for defendant. Ellis N. Slack and Andrew D. Sharpe, Washington, D. C., were on the brief.

Before JONES, Chief Judge, and LITTLETON, WHITAKER and MADDEN, Judges.

WHITAKER, Judge.

The question presented here is whether the members of this club are members of a social club and, therefore, subject to tax on initiation fees and dues paid to the club. The test is whether the social features of the club are a material purpose of its organization and maintenance or whether they are only incidental to a predominant purpose not social, such as religion, the arts, sciences, or business.

In its certificate of incorporation the...

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