concurring: While I am in agreement with the result now being reached I view it as inconsistent with Lansing Community Hotel Corporation, 14 T. C. 183, affd. (C. A. 6) 187 F. 2d 487. I thought and still think that case was erroneously decided but in the light of the present result it should in my opinion be expressly overruled. See Mullin Building Corporation, 9 T. C. 350, 358, affd. (C. A. 3) 167 F. 2d 1001.