Horwath v. Roosevelt Hotel Co.

Plaintiffs are certified public accountants and operate nationally as a copartnership. Mr. Loyd S. Pettegrew heads the firm in Los Angeles. In November of 1944, Mr. Pettegrew and Mr. Thomas E. Hull, president of defendant hotel company, had some consultations concerning an assessment proposed to be levied against defendant by the Bureau of Internal Revenue for additional income and excess profit taxes for the years 1940, 1941, 1942 and 1943.

As a result, plaintiffs were orally employed to resist the proposed assessment. A protest was prepared, and plaintiffs appeared and presented it to the…