This case having been considered by the Court on the record, briefs and oral argument on behalf of the respective parties;

And the Court being of the opinion that the ruling of the Tax Court that the $2,700 paid by petitioners for the purpose of protecting and perfecting the title to real estate in which the petitioners had an interest was a capital expenditure and not a deductible expense for income tax purposes under Section 23 (a) (1) or (2) or Section 23(e), Internal Revenue Code, 26 U.S.C.A., was not erroneous; Safety Tube Corp. v. Commissioner, 6 Cir., 168 F.2d 787, 789; Porter Royalty Pool v. Commissioner, 6 Cir., 165 F.2d 933, 936; Jones’ Estate v. Commissioner, 5 Cir., 127 F.2d 231; A. Giur-lani & Bro. v. Commissioner, 9 Cir., 119 F.2d 852, 857.

It is ordered that the judgment of the Tax Court is affirmed.