*641OPINION.
Black:The facts in this proceeding and the question involved are identical with the facts and the question in the case of Charles Colip, 5 B. T. A. 123. On the authority of the decision in that case the issue must be resolved in favor of the respondent. See also H. M. McDowell, 16 B. T. A. 95, and the cases cited therein.
Judgment will be entered for the respondent.