dissenting: I respectfully dissent for the reasons stated in the dissenting opinions filed in John W. Amos, 43 T.C. 50 (1964). My disagreement with the conclusion reached in this case, where the issue of fraud has not even been litigated in any court, is more pronounced than my disagreement with the conclusion reached by the majority in John W. Amos, supra, where the issue of criminal fraud was decided after a trial.