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CARROAD v. COMMISSIONER OF INTERNAL REVENUE

Nos. 54, 55, Dockets 21042, 21043.

172 F.2d 381 (1949)

CARROAD et al. v. COMMISSIONER OF INTERNAL REVENUE. CARROAD v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

January 31, 1949.

Attorney(s) appearing for the Case

Carroad & Carroad, of New York City (Kenneth Carroad, of New York City, of counsel; Arthur Rosenberg, of New York City, on the brief), for petitioners.

Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, A. F. Prescott, and S. Dee Hanson, Sp. Assts. to the Atty. Gen., for respondent, Commissioner of Internal Revenue.

Before AUGUSTUS N. HAND, CLARK and FRANK, Circuit Judges.

AUGUSTUS N. HAND, Circuit Judge.

Kenneth Carroad and Alexander H. Carroad, brothers, were and had long been engaged as law partners under the firm name of Carroad & Carroad, sharing partnership profits 60% and 40% respectively. Their practice which was largely in income tax matters involved much clerical and accounting work for which it was necessary for them to employ accountants and auditors and maintain a rather large clerical staff. As the accounting work...

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