Careful consideration of the claim petitioner makes, that this case on its facts is sufficiently different from the case of Virginian Hotel Corporation v. Helvering, 319 U.S. 523, 63 S.Ct. 1260, 87 L.Ed. 1561, 152 A.L.R. 871, on which the Tax Court relied, to deprive that case of binding force here, convinces us that its point is not well taken, and that the judgment of the Tax Court should, therefore, be affirmed.