Rev. Rul. 58-494

A member of a hunting and fishing club, in consideration of the office facilities furnished and services performed by him as secretary-treasurer of the club, is relieved from payment of any dues, assessments, contributions, fees, or other levies, but is entitled to the full rights and privileges of the club. Held, any member of any social, athletic, or sporting club or organization who, in consideration of the services performed or facilities furnished by him to the club, is relieved from payment of dues or membership fees is, nevertheless, liable for the tax on dues or membership fees imposed by section 4241(a)(1) of the Internal Revenue Code of 1954. The services performed and the facilities furnished by the meployee-member are equal in value, at least, to the amount paid as dues or membership fees by other members who enjoy the same rights and privileges as the employee-member, and he is liable for the tax on dues or membership fees in an amount equal to the tax paid by such other members.