concur in the dissent of Judge Black on the first issue, but also dissent from the decision of the majority on the third issue, since they believe Acampo Winery & Distilleries, Inc., 7 T. C. 629, is not effectively distinguishable.
concur in the dissent of Judge Black on the first issue, but also dissent from the decision of the majority on the third issue, since they believe Acampo Winery & Distilleries, Inc., 7 T. C. 629, is not effectively distinguishable.