This petition for review filed by the taxpayer came on to be heard on the transcript of record and on the briefs and oral arguments of attorneys for the contending parties ;

And it appearing that the findings of fact of the United States Tax Court are correctly based upon the evidence in the case and that the reasoning in the opinion of the Tax Court justifies its conclusion;

The decision of the Tax Court adjudgixig a deficiency in the taxpayer’s income tax for 1945 in the amount of $24,078.90 is ordered to be affirmed.