
    NEWTON INSERT COMPANY, Transferor, and Tridair Industries, Transferee, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
    No. 74-2501.
    United States Court of Appeals, Ninth Circuit.
    Dec. 21, 1976.
    Thomas R. Sheppard (argued), of Sheppard, Mullin, Richter & Hampton, Los Angeles, Cal., for petitioners-appellants.
    Donald H. Olson, Atty. (argued), Tax Division, U. S. Dept, of Justice, Washington, D. C., for respondent-appellee.
    Before DUNIWAY, CARTER and ANDERSON, Circuit Judges.
   PER CURIAM:

This is an appeal from a decision of the Tax Court, reported at 61 T.C. 570 (1974). For the reasons stated by the Tax Court in its opinion, we affirm.

Affirmed.  