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KEYSTONE AUTOMOBILE CLUB v. COMMISSIONER OF I. R.

No. 10097.

181 F.2d 402 (1950)

KEYSTONE AUTOMOBILE CLUB v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Third Circuit.

Decided March 30, 1950.

Attorney(s) appearing for the Case

R. Lester Moore, Philadelphia, Pa. (Todd Daniel, Philadelphia, on the brief), for petitioner.

Sumner M. Redstone, Washington, D. C. (Theron Lamar Caudle, Assistant Attorney General, Ellis N. Slack, Special Assistant to the Attorney General, on the brief), for respondent.

Before BIGGS, Chief Judge, and GOODRICH and HASTIE, Circuit Judges.

GOODRICH, Circuit Judge,

The question in this case is whether the Keystone Automobile Club must pay federal income taxes for the year 1943. The Club says that it does not have income. It also says that it is exempt under Section 101(9) of the Internal Revenue Code, 26 U.S.C.A. § 101(9). The wording of this section will be discussed later. The Commissioner's assertion of tax liability was upheld by the Tax Court.1 The taxpayer seeks...

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