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APPLICATION OF UNITED STATES (CARROLL)

No. 362, Docket 24468.

246 F.2d 762 (1957)

Application of the UNITED STATES, Appellee, for an Order compelling Earl J. CARROLL, Appellant, to comply with an Internal Revenue Summons.

United States Court of Appeals Second Circuit.

Decided July 8, 1957.

Attorney(s) appearing for the Case

Hodges, Reavis, McGrath & Downey, New York City (John P. McGrath, Martin D. Jacobs and Martin H. Proyect, New York City, of counsel), for appellant.

Paul W. Williams, U. S. Atty. for S. D. of New York, New York City (Foster Bam and Miriam R. Goldman, Asst. United States Attys., New York City, of counsel), for appellee.

Before MEDINA, LUMBARD and WATERMAN, Circuit Judges.

MEDINA, Circuit Judge.

Appellant, an American citizen, lived and practiced law in Germany for most of the time from 1946 to 1954. During that period, he numbered among his clients Alfred Krupp von Bohlen and Halback, and Frederick Flick, the German industrialists. He may have earned a substantial amount of money from his practice, but he reported none, claiming to be within the exemption of Section 116 of the Internal Revenue...

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