This appeal is from a decision of the Tax Court of the United States which determined a deficiency in the taxpayer’s income for the years 1945 through 1963. The memorandum, findings of fact and opinion of law of the Tax Court are reported at P-H Memo T.C., par. 70,064. We have considered the record, the briefs of the parties and oral arguments of counsel, and conclude that the Tax Court’s factual determinations are supported by substantial evidence and that the law was properly applied.

The decision of the Tax Court is affirmed.