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HARROLD v. COMMISSIONER OF INTERNAL REVENUE

Nos. 6286, 6287.

192 F.2d 1002 (1951)

HARROLD v. COMMISSIONER OF INTERNAL REVENUE. CROMLING v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fourth Circuit.

Decided December 7, 1951.

Attorney(s) appearing for the Case

Harry Friedman, Washington, D. C., for petitioner.

Louise Foster, Special Asst. to the Atty. Gen. (Theron Lamar Caudle, Asst. Atty. Gen., and A. F. Prescott, Special Asst. to the Atty. Gen., on brief), for respondent.

Before PARKER, SOPER and DOBIE, Circuit Judges.

SOPER, Circuit Judge.

These are petitions to review orders of the Tax Court involving income tax for the year 1945, upholding the Commissioner of Internal Revenue's disallowance of a deduction of $25,210.18, and asserting a deficiency against taxpayer Harrold in the amount of $12,935.95 and taxpayer Cromling in the amount of $11,458.04.

During the taxable year and prior thereto, the taxpayers were partners doing business

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