ESTATE of Kenneth W. DAVIS, Deceased, et al., etc., Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant

PER CURIAM:

The judgment is affirmed on the basis of the opinion of the United States Tax Court, Estate of Davis v. Commissioner of Internal Revenue, T.C.Memo. 1971-318 (1971), insofar as that opinion disposes of the Commissioner’s contention that this transaction was part gift, part sale. Affirmed.