OPINION
PER CURIAM:
The decision of the Tax Court is reversed for the reasons stated in the dissenting opinion of Judge Sterrett, Har-tung v. Commissioner, 1970, 55 T.C. 1, 5.
Jon F. and Constance M. HARTUNG, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant
484 F.2d 953
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