WIEBUSCH v. COMMISSIONER OF INTERNAL REVENUE

PER CURIAM.

The judgment in favor of the Commissioner is affirmed on the basis of the opinion of the Tax Court (Wiebusch v. Commissioner of Internal Revenue, 59 T.C. 777). The Tax Court has accurately stated the applicable law and has properly applied the law to the undisputed facts. No. purpose will be served in attempting to elaborate on the Tax Court's well-considered opinion.

Affirmed.