PER CURIAM:
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.
Appendix
T.C. Memo. 1977-401
UNITED STATES TAX COURT
MEMORANDUM OPINION
SCOTT, Judge:
Respondent...
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