concurring: As the author of Jones v. Commissioner, T.C. Memo. 1978-446, affd. 640 F.2d 745 (5th Cir. 1981), I wish to express my concurrence in the instant case not only in the result reached but also in the analysis applied by the majority. In my view, the instant case is in all material respects factually distinguishable from Jones and thus requires a different result than the result in Jones.