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WHITE v. WINCHESTER CLUB

No. 63.

315 U.S. 32 (1942)

WHITE ET AL., FORMER COLLECTORS OF INTERNAL REVENUE, v. WINCHESTER COUNTRY CLUB.

Supreme Court of United States.

Decided January 12, 1942.

Attorney(s) appearing for the Case

Mr. J. Louis Monarch, with whom Assistant Solicitor General Fahy, Assistant Attorney General Clark, and Messrs. Edward First and Richard S. Salant were on the brief, for petitioners.

Mr. Charles W. Mulcahy, with whom Mr. John P. Carr was on the brief, for respondent.

MR. JUSTICE JACKSON delivered the opinion of the Court.

We must decide whether members' payments to the Winchester Country Club for certain "privileges" constituted "dues or membership fees" subject to the tax imposed by § 501 of the Revenue Act of 1926, 44 Stat. 9, 92, as amended by § 413 of the Revenue Act of 1928, 45 Stat. 791, 864, on amounts paid "as dues or membership fees to any social, athletic, or sporting...

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