The opinion
*1400 OPINION.
Lansdon :
The issue raised by the petitioner herein has been considered by the Board in several proceedings heretofore heard, and the decisions therein have all been adverse to the theory contended for here. Harry E. Lutz, 2 B. T. A. 484; John G. Paxton, 7 B. T. A. 92; Warren E. Burns et al., 11 B. T. A. 524. Cf. Winthrop Ames, 1 B. T. A. 63. Upon authority of such decisions the determination of the Commissioner is approved.
Decision will he entered for the respondent.