dissenting: In my opinion the ratio decidendi in Moore, Inc., 4 T. C. 404; affd., 151 Fed. (2d) 527, applies with equal force here and requires the opposite conclusion to that of the majority.
dissenting: In my opinion the ratio decidendi in Moore, Inc., 4 T. C. 404; affd., 151 Fed. (2d) 527, applies with equal force here and requires the opposite conclusion to that of the majority.