Justice Jackson wrote the opinion of the court in this case. Merion Country Club sought to recover taxes from the US government for themselves and on behalf of their members. Arguing that the annual payments made to the club were not ‘dues’ or ‘membership fees’ and therefore not taxable under the code. The decision stated that the arrangement was that of a membership where the members can golf an unlimited amount for their annual fee, and therefore subject to taxation, affirming the ruling of the third circuit.