Application of the United States, for an Order Compelling Earl J. Carroll, to Comply With an Internal Revenue Summons

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' Halbaek, 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 Code of 1939 (substantially re-enacted I.R.C.1954, Section 911, 26 U.S.C.A. § 911), which applies to wages, salaries, professional fees and other amounts received as…