PER CURIAM.
This cause came on to be heard; and, upon consideration of the record, the briefs and oral argument of the attorneys for the contending parties, the decision of the tax court is affirmed on the basis of its findings of fact, all supported by substantial evidence, and for the reasons stated in its opinion, which cites Commissioner v. Tower, 327 U.S. 280, 66 S.Ct. 532, 90 L.Ed. 670, 164 A.L.R. 1135, as controlling authority.