We have examined carefully the record in this case and have given full consideration to the arguments and the briefs of the parties. No useful purpose would be served by a detailed account of the facts or of the points in controversy. We state, however, that the Tax Court did not err in it's determination of the respective- partners’ proportionate interests in the assets of the partnership, pre-incorporation. The stipulation so heavily relied on by Liberty does not compel a contrary result. We are of the opinion fthat the Tax Court correctly decided all the issues presented. - Accordingly, the decision of the Tax Court will be affirmed..