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O'CONNOR v. C. I. R.

Nos. 595-597, Docket 32576-32578.

412 F.2d 304 (1969)

Raymond A. O'CONNOR and Bertha K. O'Connor, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. BURT COLD STORAGE, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals Second Circuit.

Decided June 5, 1969.

Attorney(s) appearing for the Case

John K. O'Connor and R. R. McMahan, Chicago, Ill. (Lord, Bissell & Brook, Chicago, Ill., on the brief), for petitioners-appellants.

John P. Burke, Department of Justice (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, and Joseph M. Howard, Department of Justice, Washington, D. C., on the brief), for respondent-appellee.

Before LUMBARD, Chief Judge, ANDERSON, Circuit Judge and WYATT, District Judge.

ANDERSON, Circuit Judge:

Petitioner Raymond A. O'Connor, a certified public accountant, has conducted an accounting business in Niagara Falls, New York since 1922. From 1923 until sometime into the 1950's, he practiced in an accounting partnership with his brother Julian under the firm name of R. A. O'Connor & Company. Julian was an active member of the partnership except for the years 1943 to 1945 when he was on active duty in the United States Navy. In addition...

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