The opinion
Van Fossan,
dissenting: I can not assent to the theory that is basic in this and similar cases where a taxpayer attempts, by whatever device, to do by indirection that which the law forbids if done directly. The prevailing opinion puts the stamp of approval on a scheme that is clearly violative of the intent of Congress. Moreover, it is contrary to the well considered reasoning of the courts. See Burnet v. Wells, 289 U. S. 670 ; Willcuts v. Douglas, 73 Fed. (2d) 130.