dissenting: I agree with the views expressed in the dissenting opinion of Judge Arundell. I also adhere to those expressed in my dissents in Evelyn N. Moore, 1 T. C. 14 (on appeal, C. C. A., 2d Cir.), and Fletcher Trust Co., Trustee, 1 T. C. 798; affd., 141 Fed. (2d) 36.