OPINION.
Lansdon :On the facts as set forth above the determination of the Commissioner must be approved. Prior to December 31, 1923. *931Pincus, Sachs, and Brown owned interests in a business partnership and on that date Brown sold his share thereof to the other two partners and thereafter had no interest in the good will or other assets of the concern. Sir William Plender, 2 B. T. A. 940.
Decision will be entered for the respondent.