Citations

Full opinion text

PER CURIAM. The decision of the Tax Court finds a rational basis in John Kelley Co. v. Commissioner, 326 U.S. 521, 66 S.Ct. 299, 90 L.Ed. 278. See also Equitable Life Assur. Society v. Commissioner, 321 U.S. 560, 564, 64 S.Ct. 722, 88 L.Ed. 927. Accordingly the decision of the Tax Court will be affirmed.