
    Robert L. WILSON and Evelyn M. Wilson, (now Evelyn M. Smith), formerly husband and wife, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 19863.
    United States Court of Appeals Fifth Circuit.
    March 1, 1963.
    Amos E. Jackson, Palm Beach, Fla., for petitioners.
    Louis F. Oberdorfer, Asst. Atty. Gen.,. Lee A. Jackson, Atty., Dept. of Justice, John B. Jones, Jr., Acting Asst. Atty.. Gen., Norman H. Wolfe, Alec A.. Pandaleon, Attys., Dept. of Justice,. Crane C. Hauser, Chief Counsel, John M. Morawski, Atty., I.R.S., Washington,. D. C., for respondent.
    Before TUTTLE, Chief Judge, and POPE and JONES, Circuit Judges.
    
      
       Of the Ninth Circuit, sitting by designation.
    
   PER CURIAM.

In this ease we are in agreement with the conclusions reached by the Tax Court 37 T.C. 230. Its decision is

Affirmed.  