The opinion
Tietjens, J., concurring: In my opinion, the redemption of the certificates of purchase by the property owners was not a sale or exchange of such certificates and the gains realized by petitioner on his transactions constituted ordinary income. See Kanawha Valley Bank, 4 T. C. 252 .
Withet, FisheR, Mulronet, and Drennen, JJ., agree with this concurring opinion.