CONCURRING OPINION
Beown, Judge:I concur in the conclusion reached, for if the writer’s reasoning in J. W. Hampton, Jr. & Co. v United States 49 Treas. Dec. 593 and 616 is applicable to this plan, the result is the same.
CONCURRING OPINION
Beown, Judge:I concur in the conclusion reached, for if the writer’s reasoning in J. W. Hampton, Jr. & Co. v United States 49 Treas. Dec. 593 and 616 is applicable to this plan, the result is the same.