On authority of Commissioner of Internal Revenue v. Culbertson, decided June 27, 1949, 69 S.Ct. 1210 the decision of the Tax Court, 10 T.C. 818, is reversed ' and the cause is remanded to the Tax Court for further proceedings in conformity with the opinion of the Supreme Court of the United States in the said case of Commissioner of Internal Revenue v. W. O. Culbertson, Sr., and Gladys Culbertson.

Reversed and remanded.

Judge STEPHENS did not participate in this decision.