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ARMOUR-DIAL MEN'S CLUB, INC. v. C.I.R.

No. 81-2668.

708 F.2d 1287 (1983)

ARMOUR-DIAL MEN'S CLUB, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 2, 1983.

Attorney(s) appearing for the Case

Matthias A. Lydon, Pierce, Lydon, Griffin & Montana, John A. Dienner, III, Chicago, Ill., for petitioner-appellant.

John H. Menzel, Director, Tax Litigation Div., IRS, Michael L. Paup, Chief, Appellate Sec., Glenn L. Archer, Jr., Asst. Atty. Gen., Tax. Div., Justice Dept., Washington, D.C., for respondent-appellee.

Before CUMMINGS, Chief Judge, and WOOD and CUDAHY, Circuit Judges.

CUMMINGS, Chief Judge.

This is an appeal from a decision of the United States Tax Court sustaining the Commissioner's disallowance of certain tax deductions taken by the petitioner Armour-Dial Men's Club, Inc., on the ground that the petitioner was a "membership organization," "not exempt from taxation," "operated primarily to furnish services or goods to members," and subject to the deduction limitation in 26 U.S.C. § 277(a). We affirm.

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