concurring: It seems to me sufficient to say here that Heard v. Commissioner, 269 F. 2d 911 (C.A. 3, 1959), reversing and remanding 30 T.C. 1093, is the first ruling from a higher court on this subject, and that, accordingly, and without discussing its correctness, we propose to follow it. See Robert M. Dann, 30 T.C. 499, 510 (dissent) . I consequently concur in the result now being reached.