Arrowsmith v. Commissioner, 1952, 344 U.S. 6, 73 S.Ct. 71, 97 L.Ed. 6 and Boehm v. Commissioner, 2 Cir., 1944, 146 F.2d 553 relied on in part by plaintiffs are totally inapposite. Golconda Corporation v. Commissioner, 29 T.C. 506, (December 1957) is within the Hopkinson rule and is no authority for plaintiffs' argument, nor is Franklin A. Reece, 1955, 24 T.C. 187 applicable, dealing as it does with only the tax status of a donor.         The foregoing shall constitute Findings of Fact and Conclusions of Law in accordance with Fed.R.Civ.P. 52(a), 28 U.S.C.A.