Taxpayer seeks reversal of judgment below against taxpayer in its unsuccessful suit to recover a sum paid to the Internal Revenue Service as a deficiency income tax for the calendar years 1957 and 1958.

The judgment for defendant is affirmed on the reasoned opinion of the district judge below, 239 F.Supp. 539 and on the authority of Starr’s Estate v. Commissioner, 274 F.2d 294 (9 Cir.1959.)