See Gallun v. Commissioner, 327 F.2d 809, 810 (7th Cir. 1964), affg. a Memorandum Opinion of this Court. Barrett v. Commissioner, 42 T.C. 993, 998 (1964), affd. 348 F.2d 916 (1st Cir. 1965). Statements by commentators support a conclusion that sec. 72, like its predecessor, treats dividends paid before the maturity or surrender of a policy as a reduction of premium cost.

We also reject petitioner's contention that respondent should be estopped from collecting sales tax on the total service charge since petitioner claims it was misled by the Department's advisory letter. The second numbered paragraph of that letter states that petitioner's "total monthly charge of $25.00 is subject to tax". If petitioner was confused by the letter, it was incumbent upon petitioner to make further inquiry (see, Barrett v Commissioner of Internal Revenue, 42 T.C. 993, 1000, affd 348 F.2d 916). Judgment affirmed, without costs.