The opinion
Mellott,
dissenting: My views upon the second issue are expressed in the dissent which I filed in Morgan Jones Estate, 43 B. T. A. 691. The expenditure was made by petitioner to enable it to collect the impounded income, which the court held it was entitled to receive under its lease contract. I think the rule enunciated and applied by the Court of Appeals for the Fifth Circuit in Bliss v. Commissioner, 57 Fed. (2d) 984, is sound and should be followed.