This case arises out of the same corporate transactions which were before the Court of Claims in Davis v. United States, 26 F.Supp. 1007. It is indistinguishable in principle from Groman v. Commissioner, 302 U.S. 82, 58 S.Ct. 108, 82 L.Ed. 63, Helvering v. Bashford, 302 U.S. 454, 58 S.Ct. 307, 82 L.Ed. 367, and Hedden v. Commissioner, 3 Cir., 105 F.2d 311. The decision of the Board of Tax Appeals is affirmed upon the authority of those cases.