In Automobile Club of Michigan v. Commissioner, 353 U.S. 180, 77 S.Ct. 707, 1 L.Ed.2d 746 (1957), the Commissioner of Internal Revenue revoked a ruling which was based on an erroneous interpretation of the law. The Court upheld the Commissioner's determination that a party previously found to be tax exempt was now liable for both future and past taxes. In Automobile Club of Michigan v. Comm'r, 353 U.S. 180, 77 S.Ct. 707, 1 L.Ed.2d 746 (1957), the Court held that prepaid membership dues were properly characterized as income when received. The reasoning behind the Supreme Court's holding was that pro rata application of the dues to each month had no bearing on the services that the club had to perform when called upon.