Opinion
No. 81-7583.
Argued and Submitted May 10, 1982.
Decided June 11, 1982.
Review of Decision of the United States Tax Court.
John E. McDermott, New York City, for appellants.
Jonathan S. Cohen, Washington, D.C., for appellee.
Before KENNEDY, ALARCON, and NELSON, Circuit Judges.
The Tax Court succinctly and correctly analyzed and decided the issue below. Theo. H. Davies Co. v. C. I. R., 75 T.C. 443 (1980). We adopt the opinion of that court.
AFFIRMED.