
    Roy G. FITZGERALD, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 10115.
    Circuit Court of Appeals, Sixth Circuit.
    April 10, 1946.
    Joseph W. Sharts, of Dayton, Ohio, for petitioner.
    Sewall Key, of Washington, D. C., for respondent.
    Before HICKS, SIMONS, and MILLER, Circuit Judges.
   PER CURIAM.

This cause was heard upon the transcript of record, briefs and arguments of counsel.

On Consideration Whereof, the decision of the Tax Court entered June 23, 1945, is affirmed, upon the grounds and for the reasons set forth in its Memorandum Findings of Fact and Opinion entered June 22, 1945.  