PER CURIAM.
This cause was heard upon the transcript of record, briefs and oral arguments of counsel, and on consideration thereof, it is ordered and adjudged that the decision of the Tax Court entered on April 2, 1943, be and the same is affirmed upon the grounds and for the reasons set forth in the "Memorandum Findings of Fact and Opinion" of the Tax Court filed on January 25, 1943.