Opinion
No. 77-3986.
April 25, 1980.
David E. Ketter, Seattle, Wash., for appellant.
Richard W. Perkins, Tax Div., Dept. of Justice, Washington, D. C., argued for appellee; M. Carr Ferguson, Tax Div., Washington, D.C., on brief.
Appeal from the Tax Court of the United States.
The judgment of the Tax Court is affirmed substantially for the reasons set forth in the decision of the Tax Court reported at 68 T.C. 837 (1977).