Opinion
No. 76-4386.
December 22, 1978.
Dougal C. Pope, Houston, Tex., for defendant-appellant.
Edward B. McDonough, Jr., U.S. Atty., R. Burton Ballanfant, Anthony J. P. Farris, Asst. U.S. Attys., Houston, Tex., Scott P. Crampton, Asst. Atty. Gen., Myron C. Baum, Acting Asst. Atty. Gen., Gilbert E. Andrews, Acting Chief, Appellate Section, Jonathan S. Cohen, James S. Maxwell, Attys., Tax Div., Dept. of Justice, Washington, D.C., George Hastings, Jr., for plaintiff-appellee.
Appeal from the United States District Court for the Southern District of Texas; Carl O. Bue, Jr., Judge.
We have reviewed the forty-four page opinion of the court below from the critical viewpoint of the appellant, expressed in brief and oral argument. The district judge made detailed findings of fact which are fully supported by the record. Respecting the legal issues, we think the court below was plainly correct in resolving them as it did. The judgment is affirmed on the basis of the district court's opinion. 460 F. Supp. 1282.
AFFIRMED.