
    Samuel W. MEISEL and Rose M. Meisel, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 547, Docket 33525.
    United States Court of Appeals, Second Circuit.
    Submitted March 23, 1970.
    Decided April 3, 1970.
    Simon Presant, New York City, for appellants.
    Johnnie M. Walters, Asst. Atty. Gen., Department of Justice, Lee A. Jackson, Elmer J. Kelsey and Kenneth L. Gross, Washington, D. C., for respondent.
    Before LUMBARD, Chief Judge, HAYS, Circuit Judge, and BLUMEN-FELD, District Judge.
    
    
      
       Sitting by designation.
    
   PER CURIAM:

The judgment of the Tax Court is affirmed on the strength of its memorandum opinion. 28 T.C.M. 141 (1969). There is ample support in the record for the tax court’s factual determination that the sale by the mother to the daughter and the loans back were sham transactions.  