Supplemental Memorandum Findings of Fact and Opinion
WITHEY, Judge:
On September 29, 1966, this Court issued its Memorandum Findings of Fact and Opinion in the above-entitled cause and entered its decision in accordance therewith on January 18, 1967. On November 7, 1967, the Court of Appeals for the Seventh Circuit rendered its opinion in Tyne v. Commissioner [67-2 USTC ¶ 9721],
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