Opinion
No. 81-7757.
Argued and Submitted July 7, 1982.
Decided July 19, 1982.
Brian J. Seery, Los Angeles, Cal., for appellants.
Michael L. Paup, Ann Belanger Durney, Jay Miller, Frank P. Cihlar, Justice Dept., Tax Div., Washington, D.C., for appellee.
On Appeal from the Decision of the United States Tax Court.
Before ELY, GOODWIN, and NELSON, Circuit Judges.
Essentially upon the basis of the Tax Court's OPINION, reported at 77 T.C. 246 (1981), the decision of the Tax Court is
AFFIRMED.