concurring: I think that this case involves the same question we had before us in General Artists Corporation, 17 T. C. 1517. The distinction of the present case on the grounds that the assigned contract here does not require the “rendition of personal services” is, I believe, unwarranted. Accordingly, I concur in the result reached in the instant case, but wholly on the basis of my dissenting opinion in the General Artists Corporation case.