This petition for review was heard and' considered by the court on the record, oral arguments and briefs of attorneys for the-respective parties, and the Court being, advised;

It Is Ordered that the order of the Tax Court herein appealed from be and is hereby affirmed upon the Findings of Fact and Opinion of the Tax Court. 15 T.G. 977. See Commissioner of Internal Revenue v. Gooch Milling & Elevator Co., 320 U.S. 418, 420, 64 S.Ct. 184, 88 L.Ed. 139; Edward Barron Estate Co. v. Commissioner, 9 Cir., 93 F.2d 751; Rules 4(f) and 6(h), Rules of Practice before the Tax Court of the United States, revised to November 3, 1947, 26 U.S.C.A. § 1111; Section 42,. Chapter 65, Revised Code of Delaware.