opinion: Samuel YANOW and Reshela Yanow, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE.
  Nos. 15658, 15659.
  United States Court of Appeals Third Circuit.
  Argued March 21, 1966.
  Decided April 15, 1966.
  Herbert L. Zuckerman, Newark, N. J., for petitioners.
  Jeanine Jacobs, Tax Division, Dept of Justice, Washington, D. C. (Richard M. Roberts, Acting Asst. Atty. Gen., Lee A. Jackson, David 0. Walter, Attys., Dept, of Justice, Washington, D. C., on the brief), for respondent.
  Before KALODNER, Chief Judge, and MCLAUGHLIN and HASTIE, Circuit Judges.
  PER CURIAM:
  On this petition for review the taxpayers contend that the Tax Court erred when it held they were not entitled to take, under Section 167(a) of the Internal Revenue Code of 1954, allowances for depreciation of three properties which they owned and rented to their controlled corporations, where the rentals charged to the corporations were admittedly nominal when compared to the fair rental values of the leased properties.
  The taxpayers urge that the properties were held “for the production of income” and allowances for depreciation should be permitted for that reason.
  On review of the record we are of the opinion that the Tax Court correctly found that the properties were not held for the production of income or used in the trade or business of the taxpayer.
  The petition for review will be denied. The decision of the Tax Court will be affirmed for the reasons so well stated by Judge Train in his opinion reported at 44T.C. 444 (1965).
instruction: What follows is an opinion from a United States Court of Appeals.
  Intervenors who participated as parties at the courts of appeals should be counted as either appellants or respondents when it can be determined whose position they supported. For example, if there were two plaintiffs who lost in district court, appealed, and were joined by four intervenors who also asked the court of appeals to reverse the district court, the number of appellants should be coded as six.
  When coding the detailed nature of participants, use your personal knowledge about the participants, if you are completely confident of the accuracy of your knowledge, even if the specific information is not in the opinion. For example, if "IBM" is listed as the appellant it could be classified as "clearly national or international in scope" even if the opinion did not indicate the scope of the business. 
  
  Your task concerns the first listed appellant. The nature of this litigant falls into the category "private business (including criminal enterprises)", specifically "other". Your task is to determine what subcategory of business best describes this litigant.
choices: medical clinics, health organizations, nursing homes, medical doctors, medical labs, or other private health care facilities private attorney or law firm media - including magazines, newspapers, radio & TV stations and networks, cable TV, news organizations school - for profit private educational enterprise (including business and trade schools) housing, car, or durable goods rental or lease entertainment: amusement parks, race tracks, for profit camps, record companies, movie theaters and producers, ski resorts, hotels, restaurants, etc. information processing consulting security and/or maintenance service other service (including accounting) other (including a business pension fund) unclear