WILLIAMS, Judge.
The plaintiff, receiver of the City Club of Washington, D. C., sues to recover taxes paid on dues and admission fees of the club's members for the period from June, 1924, to April, 1930, amounting to $40,015.25. The taxes involved were collected under the provisions of section 801 of the Revenue Acts of 1918 and 1921, 40 Stat. 1121, 42 Stat. 291, section 501 of the Revenue Acts of
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