PER CURIAM:
This is an appeal from the decision of the Tax Court of the United States upholding the Commissioner of Internal Revenue in determining deficiencies in Jack C. Massengale's income tax and in determining fraud additions for the years 1961 and 1962. It is now before this court on the motion of the Commissioner for summary affirmance. We grant the motion, dismiss the appeal and affirm the Tax Court.
The findings of fact and the opinion of the court...
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