The appeal from the decision of the United States Tax Court entered March 21, 1974 having come on to be heard upon the briefs and record on appeal, and upon oral argument, upon consideration, it is ORDERED that the decision be, and it hereby is, AFFIRMED for the reasons set forth in the Memorandum Findings of Fact and Opinion of the United States Tax Court reported at 33 T.C.M. 70 (1974).