383 Opinion of the Court. Cum. Bull. 1948-2, M. T. 32, p. 160 (supra, p. 393), and none of the lower court cases, including General Motors, supra, have regarded instruments such as the Leslie Salt notes as being certificates of indebtedness. Moreover, it may be observed that in the stamp tax sections of the Internal Revenue Code of 1954 the words "certificates of indebtedness," consistently with this administrative history, have been eliminated as a separate taxable category of corporate instruments, and are employed simply as a term of art embracing all the instruments taxed, that is, "bonds," "debentures" and other instruments in registered form or with coupons. Internal Revenue Code of 1954, §§ 4311, 4381, 68A Stat. 514, 523, 26 U. S. C. §§ 4311, 4381. In contrast to the position it had consistently taken throughout the many years preceding the decision in the General Motors case, the Treasury now argues "that Congress intended in Section 1801 to cover all long-term debt obligations supported by elaborate protective covenants and that this is so regardless of the details of the papers used, the language by which the transaction was consummated or the nature of the purchaser's business." This contention seems to stem from the belief that had the "private placement" method of financing been as widely known in 1924 as it is now, Congress would not have repealed the promissory note tax in its entirety, as it did. But if that be so it is nevertheless for Congress, not the courts, to change the statute. We must deal with the statute as we find it, and if these instruments are neither vestment securities, as distinguished from instruments evidencing debts arising in ordinary transaction between individuals; and that conditional bills of sale are not certificates of indebtedness. "T. D. 2713 should be modified to conform with this holding. "ROBERT N. MILLER, "Solicitor of Internal Revenue." Opinion of the Court. 350 U.S. "debentures" nor "certificates of indebtedness" they may not be taxed under the present statute. These taxes are based not upon the nature of the transaction involved, but upon the character of the instruments employed. As long ago as 1873, this Court said: "The liability of an instrument to a stamp duty, as well as the amount of such duty, is determined by the form and face of the instrument, and cannot be affected by proof of facts outside of the instrument itself." United States v. Isham, 17 Wall. 496, 504. There are persuasive reasons for construing "debentures" and "certificates of indebtedness" in accordance with the Treasury's original interpretation of those terms in this statute's altogether comparable predecessors. In Norwegian Nitrogen Prod. Co. v. United States, 288 U. S. 294, 315, Mr. Justice Cardozo said: "administrative practice, consistent and generally unchallenged, will not be overturned except for very cogent reasons if the scope of the command is indefinite and doubtful. United States v. Moore, 95 U. S. 760, 763; Logan v. Davis, 233 U. S. 613, 627; Brewster v. Gage, 280 U. S. 327, 336; Fawcus Machine Co. v. United States, 282 U. S. 375; Interstate Commerce Commn. v. N. Y., N. H. & H. R. Co., 287 U. S. 178. The practice has peculiar weight when it involves a contemporaneous construction of a statute by the men charged with the responsibility of setting its machinery in motion, of making the parts work efficiently and smoothly while they are yet untried and new." Against the Treasury's prior longstanding and consistent administrative interpretation its more recent ad hoc contention as to how the statute should be construed cannot stand. Moreover, that original interpretation has had both express and implied congressional acquiescence, 383 Opinion of the Court. through the 1918 amendment to the statute (supra, p. 391), which has ever since continued in effect, and through Congress having let the administrative interpretation remain undisturbed for so many years. See Corn Products Refining Co. v. Commissioner, 350 U. S. 46, 53; Norwegian Nitrogen Prod. Co. v. United States, supra, at p. 313.13 Still further, it is an interpretation which is in accord with the generally understood meaning of the term "debentures." Cf. First Nat. Bank v. Flershem, 290 U. S. 504, 508. "The words of the statute [a stamp tax statute] are to be taken in the sense in which they will be understood by that public in which they are to take effect." United States v. Isham, supra, at p. 504. 14 13 It should be said that the administrative practice, which we consider as crucial here, was not brought to the attention of the Court of Appeals in Niles-Bement-Pond Co. v. Fitzpatrick, supra. Nor do General Motors Acceptance Corp. v. Higgins, supra, or any of the cases cited in note 4, supra, advert to that practice. 14 As long ago as 1916, no less an authority on corporate finance than the late Mr. F. L. Stetson described debentures in the following terms: "In the United States, as already mentioned, the term 'debenture' is understood to mean serial obligations of a corporation not secured by a specific mortgage, pledge or assignment of property. Of course a series of debentures may be issued without the execution of any indenture relating thereto. Prior to 1900 the few issues that had been made of such debentures were not accompanied by a trust agreement. In such case the rights and privileges given to bondholders were set forth at length in the obligation, thus making a somewhat lengthy instrument. Since an issue of debentures under trust agreements by the Lake Shore R. R. Co. and by the New York Central, the custom of adopting such agreements has become general. Originally in 1893 the General Electric Company made a large issue of debentures without an agreement, but at the time of the refunding in 1912 a trust agreement was executed." "Preparation of Corporate Bonds, Mortgages, Collateral Trusts and Debenture Indentures," in Some Legal Phases of Corporate Financing, Reorganization and Regulation, p. 66 (Assn. of the Bar of the City of New York, 1917). Opinion of the Court. 350 U.S. Construing the statute as we have, we conclude that the Leslie Salt notes are neither "debentures" nor "certificates of indebtedness" within its meaning. The fact that the agreement underlying these notes provides for the substitution of instruments which might qualify as debentures does not render these notes taxable, for until debentures are in existence the "debenture" tax cannot be imposed. We hold these notes are not subject to stamp taxes under the statute. Affirmed. Opinion of the Court. CAMMER v. UNITED STATES. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT. No. 110. Argued January 24, 1956.-Decided March 12, 1956. A lawyer is not the kind of "officer" who can be tried summarily for contempt under 18 U. S. C. § 401 (2), which empowers a court of the United States to punish as contempt "Misbehavior of any of its officers in their official transactions." Pp. 399–408. (a) This section derives from the Contempt Act of March 2, 1831, 4 Stat. 487, and should be narrowly construed because its legislative history shows that Congress intended drastically to limit. the contempt power of federal courts and because the exercise of any broader contempt power would permit too great inroads on the procedural safeguards of the Bill of Rights. Pp. 403-404. (b) The term "officers," as used in 18 U. S. C. § 401 (2), should not be expanded beyond the group of persons-such as marshals, bailiffs, court clerks and judges-who serve as conventional court officers and are regularly treated as such in the laws. P. 405. (c) The legislative history of the 1831 Act is completely inconsistent with a purpose to treat lawyers as "officers of the court" subject to summary punishment. Pp. 405-408. U. S. App. D. C. —, 223 F. 2d 322, reversed. Charles E. Ford argued the cause and filed a brief for petitioner. Gray Thoron argued the cause for the United States. With him on the brief were Solicitor General Sobeloff, Assistant Attorney General Olney, Beatrice Rosenberg and Richard J. Blanchard. MR. JUSTICE BLACK delivered the opinion of the Court. 18 U. S. C. § 401 (2) empowers a court of the United States to punish as contempt "Misbehavior of any of its |