KRAMPF v. COMMISSIONER OF INTERNAL REVENUE

PER CURIAM:

A careful examination of the briefs and the record and consideration of the oral arguments convinces us that there is no error in the decision of the Tax Court. The decision of the Tax Court will be affirmed on the careful opinion of Judge William H. Quealy, 56 T.C. 293. Cf. Opal v. Commissioner of Internal Revenue, 450 F.2d 1085 (2 Cir. 1971).