¶1Rames J. Bucei, Philadelphia, Pa., for petitioner. ,
¶2S. Dee Hanson, Washington, D. C. ■(Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, A. F. Prescott, Sp. Assts. to the Atty. Gen., on the brief), for respondent.
¶3Before BIGGS, Chief Judge, and Mc-LAUGHLIN. and O’CONNELL, Circuit Judges.
¶5We have examined with care the record in the instant case and the arguments of the parties. The appeal is without merit' Accordingly . the decision of the Tax Court will be affirmed.