VOGEL, Circuit Judge.
James M. Kemper, petitioner herein, seeks review of a decision of the Tax Court of the United States whereby the Tax Court upheld a deficiency in Kemper's income tax in the amount of $10,300.35 for the year 1954. Jurisdiction is invoked under § 7482(a), I.R.C., 26 U.S. C.A. (I.R.C.1954) § 7482(a). The findings of fact and opinion of the Tax Court are reported in
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