USCA1 Opinion

          February 26, 1996

                                [NOT FOR PUBLICATION]

                            UNITED STATES COURT OF APPEALS

                                FOR THE FIRST CIRCUIT

                                 ____________________



        No. 95-1749



                                  GERALD T. PETERS,



                                Petitioner, Appellant,



                                          v.



                          COMMISSIONER OF INTERNAL REVENUE,



                                Respondent, Appellee.





                                 ____________________



                       APPEAL FROM THE UNITED STATES TAX COURT



                        

                   [Hon. D. Irvin Couvillion, U.S. Tax Court Judge]
                                              ____________________



                                 ____________________



                                        Before



                                Torruella, Chief Judge,
                                           ___________

                            Selya and Cyr, Circuit Judges.
                                           ______________



                                 ____________________



            Gerald T. Peters on brief pro se.
            ________________

            Loretta C.  Argrett, Assistant  Attorney General,  Gary R.  Allen,
            ___________________                                ______________

        William S. Estabrook and  Murray S. Horwitz, Attorneys, Tax  Division,
        ____________________      _________________

        Department of Justice, on brief for appellee.





                                 ____________________





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                      Per Curiam.  Gerald Peters appeals from a Tax Court
                      __________



            decision  assessing a tax deficiency against him for the 1991



            tax  year.   He also  appeals from  the Tax  Court's decision



            denying  his motion  for administrative and  litigation costs



            under 26 U.S.C.    7430.  After careful consideration  of his



            claims  on appeal,  we  affirm, essentially  for the  reasons



            given  in the Tax Court's decision filed on December 2, 1994,



            and in its order dated February 6, 1995.



                      Affirmed.  See Loc. R. 27.1.
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