
    WARREN JONES COMPANY, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.
    No. 77-3986.
    United States Court of Appeals, Ninth Circuit.
    April 25, 1980.
    David E. Ketter, Seattle, Wash., for appellant.
    Richard W. Perkins, Tax Div., Dept. of Justice, Washington, D. C., argued for appellee; M. Carr Ferguson, Tax Div., Washington, D. C., on brief.
    Before GOODWIN and FERGUSON, Circuit Judges, and WILLIAMS, District Judge.
    
      
       The Honorable Spencer M. Williams, United States District Judge for the Northern District of California, sitting by designation.
    
   The judgment of the Tax Court is affirmed substantially for the reasons set forth in the decision of the Tax Court reported at 68 T.C. 837 (1977).  