John P. GAWLER and Annabel C. Gawler, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee; Robert H. MYERS and Antoinette H. Myers, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee; Katherine L. SIMMONS, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee; John H. MYERS and Eleanor B. Myers, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee; Berkeley L. SIMMONS, Jr., and Virginia T. Simmons, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee; Robert L. SIMMONS, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee, 504 F.2d 425

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.