dissenting: I can not concur in the entire opinion, for it seems to me that, as to some of the dividends, the decisions of the United States Circuit Court of Appeals for the Third Circuit (the *247circuit in which, these petitioners reside), in United States v. Mellon, 281 Fed. 645, and United States v. Davison, 9 Fed. (2d) 1022, are contrary to the decision here made.
Teussell agrees with the dissent.