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HANOVER BANK v. COMMISSIONER

No. 224.

369 U.S. 672 (1962)

HANOVER BANK, EXECUTOR, ET AL. v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided May 21, 1962.

Attorney(s) appearing for the Case

Theodore Tannenwald, Jr. argued the cause for petitioners. With him on the briefs was David Alter. Horace S. Manges was on the petition.

Stephen J. Pollak argued the cause for respondent. With him on the briefs were Solicitor General Cox, Assistant Attorney General Oberdorfer, Meyer Rothwacks, Douglas A. Kahn and Wayne G. Barnett.

A brief urging reversal was filed by William Waller, as amicus curiae.

MR. CHIEF JUSTICE WARREN delivered the opinion of the Court.

Despite the seemingly complex factual composition of the two cases consolidated herein,1 this opinion deals with a relatively simple question of taxation: The extent to which a taxpayer may deduct, through amortization under the Internal Revenue Code of 1939, the premium he has paid in purchasing corporate bonds. In 1953, prior to December...

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