Nos. 12787 and 12811, in court of appeals for 5th circuit, Roy Burns, E. A. Jackson and Mary George Frizzell, executors of estate of James E. Frizsell, v. commissioner of internal revenue; commissioner of internal revenue v. Roy Burns, E. A. Jackson and Mary George Frizzell, executors of estate of James E. Frizzell, on petitions for review of decision of Tax Court; brief for commissioner.