ANDERSON, District Judge.
The taxpayer, Parkchester Beach Club Corp., owned approximately thirty acres of real property in the Borough of the Bronx, New York City, which it used in the operation of its business of furnishing park and recreational facilities, including a beach, swimming pool, picnic area, tennis courts, handball courts, basketball courts, and eating places. These services and facilities were available only to members of Shorehaven Beach Club, Inc....
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