This case was consolidated with John Hancock Mutual Life Insurance Company v. Commissioner of Internal Revenue in the Board of Tax Appeals, 42 B.T.A. 809. They were heard here together. The parties agree that the single question of law is the same in both cases. Hence the opinion of the Hancock case, - App.D.C. -, 128 F.2d 745, decided this day, is controlling.

Reversed.