The above cause coming on to be heard upon the record, the briefs of the parties, and the argument of counsel in open court, and it appearing that the findings of fact, opinion and decision of the Tax Court were not clearly erroneous; and the court being duly advised,

Now therefore, It is Ordered, Adjudged and Decreed that the decision herein reviewed be and is hereby affirmed, in accordance with the findings of fact and opinion of the Tax Court.