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COMMISSIONER OF INT. REV. v. THE CHARLESTON NAT. BANK

No. 6755.

213 F.2d 45 (1954)

COMMISSIONER OF INTERNAL REVENUE v. THE CHARLESTON NAT. BANK, CHARLESTON, W. VA.

United States Court of Appeals, Fourth Circuit.

Decided May 19, 1954.

Attorney(s) appearing for the Case

Karl Schmeidler, Sp. Asst. to Atty. Gen. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Alonzo W. Watson, Sp. Assts. to Atty. Gen., on brief), for petitioner.

Charles M. Love, Charleston, W. Va. (Dayton, Campbell & Love, Charleston, W. Va., on brief), for respondent.

Before PARKER, C. J., and SOPER and DOBIE, JJ.

SOPER, Circuit Judge.

The question in this case is whether, as the Tax Court held (20 T.C. 253), the Charleston National Bank, in computing its income tax for the years 1944 and 1945, was entitled to deduct as ordinary and necessary business expenses under § 23(a) of the Internal Revenue Code, 26 U.S.C.A., certain premiums which it paid in those years on life insurance policies held by it as collateral security for monies loaned...

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