
    KENYATTA CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
    No. 86-7292.
    United States Court of Appeals, Ninth Circuit.
    Argued and Submitted March 4, 1987.
    Decided March 12, 1987.
    Arthur H. Boelter, Seattle, Wash., for petitioner-appellant.
    Ann Belanger Durney, and Francis M. Allegra, Washington, D.C., for respondentappellee.
    Before GOODWIN, SCHROEDER and FARRIS, Circuit Judges.
   ORDER

The judgment of the Tax Court is affirmed for the reasons stated in the published opinion of the Tax Court. Kenyatta Corporation v. Commissioner of Internal Revenue, 86 T.C. 171 (Feb. 12, 1986).  