¶1Louis Janin, of San Francisco, Cal., for petitioner.
¶2Douglas W. McGregor, Asst. Atty. Gen., Sewall Key, Robert N. Anderson, and Maryhelen Wigle, Sp. Assts. to Atty. Gen., for respondent.
¶3Before GARRECHT, HEALY, and BONE, Circuit Judges.
¶5The decision of the Tax Court is hereby affirmed.