TAXATION - EXCISE TAXES - MEANING OF DUES OR MEMBERSHIP FEES UNDER THE FERERAL REVENUE ACTS

The Winchester Country Club's by-laws provided for "annual dues" of fifty dollars which entitled the member to all the privileges of the club except golf. By paying fifty dollars more for "full privileges," members obtained the privilege of playing golf for a year. The club's practice was to bill members annually in advance, measured by the privileges previously held. If after such billing a member indicated that he did not want the golf privilege, no attempt was made to collect the charge.

The federal government collected taxes on payments to the club for golf privileges on the ground that the payments were "dues or membership fees." After a claim for refund had been rejected, the club sued as agent for its members to recover the taxes paid. Held, the charges for golf privileges were taxable as club "dues or membership fees" within the meaning of the Revenue Act. White v. Winchester Country Club, (U.S. 1942) 62 S. Ct. 425.