PER CURIAM.
This case was reargued and has also been reconsidered on the record and on the briefs of counsel; and it apearing that the findings of fact of the United States Tax Court are supported by substantial evidence and its conclusions justifiably drawn, and that the position of the petitioning taxpayer is less strong than was that of the petitioner in Commissioner v. Tower, 66 S.Ct. 532, decided February 25, 1946, the decision of the Tax Court is affirmed.