dissenting: The present result seems to me utterly irreconcilable with that in Estate of Charles H. Wiggin, 3 T. C. 464, even as that case is interpreted for purposes of distinction in Estate of Edwin E. Jack, 6 T. C. 241, 246. See Estate of Eunice M. Greene, 11 T. C. 205. If the Wiggin case is erroneous, a due regard for reasonably definite and consistent rules for the guidance of taxpayers seems to me to require that it be explicitly overruled.
Tukner, /., agrees with this dissent.