dissenting: In view of the regulations (secs. 1.482-1 (a) (6), (b), (c), (d) (4), and 1.482-2(a), Income Tax Regs.), promulgated after many of the cases relied upon by the majority were decided, I respectfully dissent. My views are stated in a dissenting opinion in Kerry Investment Co., 58 T.C. 479 (1972).