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AUTOMOBILE CLUB v. COMMISSIONER

No. 89.

353 U.S. 180 (1957)

AUTOMOBILE CLUB OF MICHIGAN v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided April 22, 1957.

Attorney(s) appearing for the Case

Ellsworth C. Alvord and Raymond H. Berry argued the cause for petitioner. With them on the brief were A. H. Moorman and Lincoln Arnold.

John N. Stull argued the cause for respondent. With him on the brief were Solicitor General Rankin, Assistant Attorney General Rice, I. Henry Kutz and Joseph F. Goetten.

MR. JUSTICE BRENNAN delivered the opinion of the Court.

In 1945, the Commissioner of Internal Revenue revoked his 1934 and 1938 rulings exempting the petitioner from federal income taxes, and retroactively applied the revocation to 1943 and 1944. The Commissioner also determined that prepaid membership dues received by the petitioner should be taken into income in the year received, rejecting the petitioner's method of reporting as income only that part of the dues...

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