Scofield v. Corpus Christi Golf & Country Club‪.‬

The suit was for tax refund. The claim was that plaintiff, within Section 101, Revenue Act of 1936, 26 U.S.C.A. Int. Rev. Code 101, was a Club "organized and operated exclusively for pleasure, recreation, and other nonprofitable purposes, no part of the net earnings of which inures to the benefit of any private shareholder." The defense was that, in the year in question, the Club executed an oil lease upon its club property, for a consideration of a cash bonus, reserved oil payments and a royalty and in that year received, $11,554.46, $7,500 as bonus, and $4,004.44 as royalty, and therefore was not, within the exemption, being operated exclusively for pleasure, recreation and other non-profitable purposes. On stipulated facts, showing that the operations conducted by the Club continued to be the same before as after the lease, that all operations under the lease were conducted by the lessee, none by the Club, and that not a dollar of the net earning inured to the benefit of any private shareholder, the district judge found for plaintiff and gave judgment accordingly.