
    COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. TITLE & TRUST COMPANY, a corporation, Respondent.
    No. 12954.
    United States Court of Appeals Ninth Circuit.
    Dec. 11, 1951.
    Ellis N. Slack, Acting Asst. Atty. Gen., Harry Marselli, Sp. Asst. to Atty. Gen., for petitioner.
    Clarence D. Phillips, Portland, Or. (Griffith, Phillips & Coughlin, Portland, Or., of counsel), for respondent.
    Before MATHEWS, STEPHENS and POPE, Circuit Judges.
   PER CURIAM.

The decision of the Tax Court is affirmed on the grounds and for the reasons stated ' in its opinion, 15 T.C. 510, and cases there cited.  