No. 78-1581. Summary Calendar.
Rule 18, 5 Cir.; See Isbell Enterprises, Inc. v. Citizens Casualty Co. of New York et al., 5 Cir., 1970, 431 F.2d 409, Part I.
November 16, 1978.
Howard A. Lang, Jr., Houston, Tex., for petitioner-appellant.
M. Carr Ferguson, Asst. Atty. Gen., Tax Div., Gilbert E. Andrews, Acting Chief, U.S. Dept. of Justice, Stuart E. Seigel, Acting Chief Counsel, Washington, D.C., for respondent-appellee.
Appeal from the Decision of the Tax Court of the United States.
Before MORGAN, CLARK and TJOFLAT, Circuit Judges.
James W. Williams appeals an order of the tax court finding a deficiency in his income taxes for the year 1971 in the amount of $87,810. Finding the disposition of the tax court to be correct, we affirm on the basis of that court's opinion, which is appended hereto.