It is ordered and adjudged that the decision of the Board of Tax Appeals be and is affirmed upon the grounds and for the *1010reasons stated in the findings of fact and opinion of the Board reported in 37 B.T.A. 806.
It is ordered and adjudged that the decision of the Board of Tax Appeals be and is affirmed upon the grounds and for the *1010reasons stated in the findings of fact and opinion of the Board reported in 37 B.T.A. 806.