ORDER OF AFFIRMANCE

Upon a' careful consideration of the record, the briefs, and the arguments of the parties, the Court has concluded that the judgment of the Tax Court, unofficially reported at P—H Memo. T.C. ¶ 74—274, is based on findings that are not clearly erroneous, that no error of law appears, and that an opinion would have no precedential value. For these reasons, the judgment appealed from is hereby affirmed on the basis of the opinion of the Tax Court.