*761OPINION.
Graupner:This appeal is based upon the same transactions in stock as -were involved in the Appeals of W. G. Schroth and John G. Schroth, 2 B. T. A. 169. Those appeals were submitted on the pleadings. In the present appeal counsel stipulated the major facts and oral evidence was offered, but there is nothing in either the stipulation or the evidence to convince us that ive should modify our decision in the two appeals which have been decided.
ARundell not participating.