*661OPINION.
Marquette:The facts herein are not materially different from the facts in Russell Tyson et al., Trustees, 20 B. T. A. 597. Upon the authority of the decision therein, the petitioner is held to constitute an association and is taxable as a corporation.
Reviewed by the Board.
Judgment will be entered for the respondent.
Teammell and Yan Fossan dissent.