Opinion
No. 71-1792.
Argued September 11, 1972.
Decided September 27, 1972.
Stanley Zucker, Kane Zucker, New York City, for appellant.
William M. Brown, Jr., Dept. of Justice, Tax Div., Washington, D.C. (Meyer Rothwacks, Elmer J. Kelsey, Attys., Tax Div. Dept. of Justice, Washington, D.C., Scott P. Crampton, Asst. Atty. Gen., on the brief), for appellee.
Appeal from United States Tax Court; William Quealy, Judge.
Before BIGGS, JAMES ROSEN and HUNTER, Circuit Judges.
OPINION OF THE COURT
A careful examination of the briefs and the record and consideration of the oral arguments convinces us that there is no error in the decision of the Tax Court. The decision of the Tax Court will be affirmed on the careful opinion of Judge William H. Quealy, 56 T.C. 293. Cf. Opal v. Commissioner of Internal Revenue, 450 F.2d 1085 (2 Cir. 1971).