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HALLE v. UNITED STATES

Civ. No. 14689.

232 F.Supp. 462 (1964)

Milton L. HALLE and Rachel N. Halle, his wife, v. UNITED STATES of America.

United States District Court D. Maryland.

August 13, 1964.

Attorney(s) appearing for the Case

Eugene H. Schreiber, Baltimore, Md. (Charles M. Cahn, Jr., and Blades & Rosenfeld, Baltimore, Md., on brief), for plaintiffs.

Moshe Schuldinger, Atty., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., C. Moxley Featherston, David A. Wilson, Jr., Attys., Dept. of Justice, Washington, D. C., and Thomas J. Kenney, U. S. Atty., and Robert W. Kernan, Asst. U. S. Atty., Baltimore, Md., on brief), for defendant.

THOMSEN, Chief Judge.

This is an action for the recovery of income taxes and interest alleged to have been illegally assessed. Taxpayers claimed deductions for amortization of bond premiums and for interest expense, as well as for a charitable contribution, arising out of the transaction set forth in the statement of facts, below. The Commissioner allowed the charitable deduction, but disallowed the deductions for amortization and interest on the ground that they...

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