Justice Jackson wrote the opinion for the court in this case as well, as this was a companion case to Merion Country club. The first circuit decided differently on this case, which is factually quite similar to Merion. As in Merion, the country club was suing the United States on behalf of its membership for taxing payments that they did not consider ‘dues’ or ‘membership fees’. Jackson, wrote the opinion for the court, and reversed the decision of the first circuit clarifying that yearly fees to use the club and the golf course were in fact taxable membership fees or dues according to the tax code.