David C. HAKIM and Margaret K. Hakim, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee

ORDER

Before WEICK, McCREE and MILLER, Circuit Judges.

The appeal from the decision of the Tax Court having come on to be heard upon the record on appeal, briefs and oral argument, upon consideration, it is ORDERED that the decision is hereby AFFIRMED for the reasons set forth in the memorandum of Judge Drennen.