This cause came on to be heard and considered upon the whole record and upon the oral arguments and printed briefs of the attorneys for the petitioner and the respondent, respectively;

And the Court being of opinion that, on the basis of the determinative findings of fact of the Tax Court which are supported by substantial evidence and are not clearly erroneous and for the reasons stated in its opinion;

The decision of the Tax Court should be, and the same is hereby ordered to be, affirmed.