¶1•John D. Worlman, of Akron, Ohio, for petitioner.
¶2Theron L. Caudle, of Washington, D. C., for respondent.
¶3Before MARTIN, McALLrSTER, and MILLER, Circuit Judges.
¶5This cause came on to be heard on the record and on the briefs and oral arguments of attorneys for the contending parties; and it appearing that the decision of *69the tax court, based on its findings of fact supported by substantial evidence, is correct for the reasons stated in the court’s opinion; the decision of the tax court is affirmed.