Laurie W. TOMLINSON, District Director of Internal Revenue, Appellant, v. Hubert RUTLAND and Ruth Rutland, his wife, Appellees

PER CURIAM.

The facts here presented are different only in detail from those in Commissioner v. Birch Ranch and Oil Co., 9th Cir. 1951, 192 F.2d 924, affirming Birch Ranch and Oil Co. v. Commissioner, 13 T.C. 930. The principles there stated are sound and require the affirmance of the district court. Affirmed.