ORDER.

This case is before the Court on petition of the Commissioner of Internal Revenue for review of the decision of the Tax Court of the United States.

Upon consideration of the record, the briefs and oral arguments of counsel, the Court finds that the legal conclusions of the judge of the Tax Court based on the stipulated facts, which are reviewed in his opinion, are correct and in accordance with a proper interpretation of the statute involved. Section 355, Title 26 U.S.C. (I.R.C. 1954).

*491 It is therefore ordered and adjudged that the decision of the Tax Court be and it is hereby affirmed on the opinion of Judge Tietjens reported at 33 T.C. 771.