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The whistle was introduced by Lionel in the 1935 catalog.  The 400E is one of the locomotives shown with a whistle tender - 400W.  Same in 1936.

Also shown in the 1935 catalog are repalcement tenders that you could buy to add a whistle to an older locomotive.

From these facts, one could infer that if the 400E was from 1934 or earlier, the whistle was in a replacement tender.  From 1935 on, it was probably original equipment.

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