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Full opinion text

PER CURIAM:

Appeal from the decision of the Tax Court which is reported at 52 T.C. 478. We are of the Opinion that the decision should be affirmed for the reasons stated in the opinion of the Tax Court. See also Minot Fed. Sav. & Loan Assn. v. United States, 8 Cir., 1970, 435 F.2d 1368.

Affirmed.