PER CURIAM.
We have reviewed the findings of fact and the opinion of the Tax Court and perceive no error therein. The decision in favor of the Commissioner will be affirmed on the well reasoned opinion of Judge Atkins.
No cited authorities resolved to law.co cases yet.
PER CURIAM.
We have reviewed the findings of fact and the opinion of the Tax Court and perceive no error therein. The decision in favor of the Commissioner will be affirmed on the well reasoned opinion of Judge Atkins.