December 19, 1977
FON S. LEONG AND EILEEN LEONG, APPELLANTS
COMMISSIONER OF INTERNAL REVENUE, APPELLEE.
Before FRIENDLY, SMITH and MESKILL, Circuit Judges.
This cause came on to be heard on the transcript of record from the United States Tax Court, and was argued by counsel.
ON CONSIDERATION WHEREOF, it is now hereby ordered, adjudged, and decreed that the Decision of said Tax Court be and it hereby is affirmed on the Memo of Judge Tannenwald, T.C. Memo 1977-19 (Jan. 31, 1977).
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