The opinion
HUTCHESON, Circuit Judge
(concurring specially).
I concur in all that the majority has said, but I should like to add that in my opinion the Tax Court erred in not recognizing that Mrs. Brown who had been a Vice-President since 1926, did actually perform service in having her name standing at the masthead of a corporation of this character. I think it was an arbitrary fiat and not a finding of fact for the Tax Court to substitute its judgment for that of the management and determine that in thus standing for years as Vice-President, ready, able and willing to discharge the duties of that office and of the office of the President, if his absence or disability called her to that performance, Mrs. Brown was not rendering service to the company for which she should be adequately paid,