WILLIAM E. DOYLE, Circuit Judge.
This is an appeal by the Commissioner of Internal Revenue from an unfavorable ruling by the United States Tax Court. The Commissioner determined deficiencies in the taxpayer's federal income tax for the years 1968, 1969 and 1970, amounting to $48,143.43, $115,363.38 and $92,842.58. The Tax Court reversed and redetermined the deficiencies in the amounts of $1,666.25 for 1968, $1,633.49 for 1969, and $1,588.74 for 1970.
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