Raymond A. O'COnnOr and Bertha K. O'COnnOr v. Commissioner of Internal Revenue, Burt Cold Storage, Inc. v. Commissioner of Internal Revenue

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 to his accounting practice, Raymond operated two farms owned by his wife, Bertha, managed a canning plant, was treasurer and sole…