PER CURIAM:
Judge Winter and Judge Craven agree that the judgment of the tax court should be affirmed for the reasons set forth in the opinion of Judge Tannen-wald, writing for the majority in Gawler v. Commissioner, 60 T.C. 647 (1973); while Judge Boreman would reverse for the reasons set forth by Judge Drennen, dissenting in that case.
Affirmed.