3d 545 (2009)
KEYES
v.
McCARTHY.
No. 5D08-3570.
District Court of Appeal of Florida, Fifth District.
September 22, 2009.
Decision without published opinion Affirmed.



125 F.2d 611 (1942)
HASSETT, Former Acting Collector of Internal Revenue,
v.
ASSOCIATED HOSPITAL SERVICE CORPORATION OF MASSACHUSETTS.
No. 3708.
Circuit Court of Appeals, First Circuit.
February 4, 1942.
*612 *613 Lyle M. Turner, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., J. Louis Monarch, Sp. Asst. to Atty. Gen., and Edmund J. Brandon and George F. Garrity, both of Boston, Mass., on the brief), for appellant.
Roger W. Hardy, of Boston, Mass., for appellee.
Before MAGRUDER, MAHONEY, and WOODBURY, Circuit Judges.
MAHONEY, Circuit Judge.
The plaintiff brought this action to recover taxes alleged to have been assessed and collected illegally under Title VIII of the Social Security Act of 1935, 49 Stat. 636, 639, 42 U.S.C.A. § 301 et seq., on the ground that the plaintiff is exempt from the act being "a corporation * * * organized and operated exclusively for * * * charitable * * * purposes * * * no part of the net earnings of which inures to the benefit of any private shareholder or individual".[1] The District Court gave judgment for the plaintiff holding that it was such a corporation. The defendant has appealed.
The plaintiff, Associated Hospital Service Corporation of Massachusetts, was organized in March, 1937, under the provisions of Chapter 176A of the General Laws of Massachusetts (Ter.Ed.) as added by Chapter 409 of the Acts of 1936. The statute provides for the organization of corporations for the purpose of operating a non-profit hospital service plan whereby hospital care may be provided for subscribers to the plan under contracts which entitle subscribers to certain hospital care.
Membership in the corporation was made up of voting members, members-at-large and the participating hospital members. The voting members include Trustees and Executive Committee of Hospital Council of Boston, Massachusetts Hospital Associ