678 F.2d 1367: Theodore H. Davies & Co., Ltd. & Subsidiaries, Appellants, v. Commissioner of Internal Revenue, Appellee
United States Court of Appeals, Ninth Circuit. - 678 F.2d 1367
Argued and Submitted May 10, 1982.Decided June 11, 1982
Review of Decision of the United States Tax Court.
John E. McDermott, New York City, for appellants.
Jonathan S. Cohen, Washington, D. C., for appellee.
Before KENNEDY, ALARCON, and NELSON, Circuit Judges.
The Tax Court succinctly and correctly analyzed and decided the issue below. Theo. H. Davies & Co. v. C. I. R., 75 T.C. 443 (1980). We adopt the opinion of that court.