¶1Henry B. Twombly, of New York City, for petitioner.
¶2Leonard Sarner, of Washington, D. C., (Sewall Key, Acting Asst. Atty. Gen., and Helen R. Carloss, Sp. Asst. to Atty. Gen., on the brief), for respondent.
¶3Before BIGGS, GOODRICH, and O’CONNELL, Circuit Judges.
¶5Examination of the record in this case and consideration of the briefs and arguments of the parties convince us that the Tax Court reached the correct decision. Accordingly the decision is affirmed.