¶1Mr. Philip G. Sheehy for petitioner. Mr. Andrew D. Sharpe, with whom Solicitor General Reed, Assistant Attorney General Morris, and Messrs. Sewall Key, Norman D. Keller, and Lee A. Jackson were on the brief, for respondent. By *619leave of Court, Mr. W. H. Morrissey filed a brief on behalf of the San Mateo County Title Co., as amicus curiae, in support of petitioner.
¶3The judgment is affirmed. Tyler v. United States, 281 U. S. 497; Gwinn v. Commissioner, 287 U. S. 224.
¶4Mr. Justice Cardozo and Mr. Justice Reed took no part in the consideration or decision of this case.