Opinion
No. 87-7417.
Argued and Submitted May 3, 1988.
Decided July 5, 1988.
Timothy S. Harris, Los Angeles, Cal., for petitioner-appellant.
Kenneth L. Greene, Dept. of Justice, Washington, D.C., for respondent-appellee.
Appeal from a Decision of the Tax Court of the United States
ORDER
We affirm the judgment substantially for the reasons stated by the Tax Court in its opinion in 88 T.C. 1384 (1987).