N. Louis Stone v. Commissioner of Internal Revenue

COFFIN, Circuit Judge.

Taxpayers, husband and wife, seek to review a Tax Court decision disallowing amortization deductions taken in 1952 and 1953 (in the respective amounts of $7,-756.70 and $5,896.82) for premiums paid on the purchase of callable bonds.

The law applicable to this case is the Internal Revenue Code of 1939, Sections 23 (v) and 125. 1 The combined effect of these sections was to allow as a deduction from net income the difference between the purchase price of a bond (more accurately, the taxpayer’s basis in the event of sale) and the amount payable if the bond were called. 2

The…