
    Charles C. D. GOTT, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 188, Docket 22875.
    United States Court of Appeals Second Circuit.
    Argued April 8, 1954.
    Decided April 27, 1954.
    John R. Brook, George V. Mahoney, New York City, for petitioner.
    H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, C. Moxley Featherston, Sp. Assts. to the Atty. Gen., for respondent.
    Before CHASE, Chief Judge, and SWAN and FRANK, Circuit Judges.
   PER CURIAM.

Affirmed on the opinion of the Tax Court, 12 T.C.M. 435.

Bogardus v. Commissioner, 302 U.S. 34, 58 S.Ct. 61, 82 L.Ed. 32, on which the petitioner much relies, is distinguishable on the facts.  