William J. Brennan, Jr.

“ In 1945, the Commissioner of Internal Revenue revoked his 1934 and 1938 rulings exempting the petitioner from federal income taxes, and retroactively applied the revocation to 1943 and 1944. The Commissioner also determined that prepaid membership dues received by the petitioner should be taken into income in the year received, rejecting the petitioner's method of reporting as income only that part of the dues as was recorded on petitioner's books as earned in the tax year. ”

“ These regulations provided that when an organization had established its right to exemption it need not thereafter make a return of income or any further showing with respect to its status unless it changed the character of its operations or the purpose for which it was originally created. ”

“ Club v. Commissioner, (Warren Auto. Club v. Commissioner) , 6 Cir., 182 F.2d 551; Keystone Auto. Club v. Commissioner, 3 Cir., 181 F.2d 402; Smyth v. California State Auto. Ass'n, 9 Cir., 175 F.2d 752; Automobile Club of St. Paul v. Commissioner, 12 T.C. 1152.↑ Section 275 (a) provides as follows:↑ The 1943 tax return was due on March 15, 1944. The 1944 tax return was due on March 15, 1945.↑ To the extent that the decision in Balkan Nat. Ins. Co. ”