UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 96-1385

WILLIAM L. PATCH, Petitioner - Appellant, versus COMMISSIONER OF THE INTERNAL REVENUE SERVICE, Respondent - Appellee.

On Appeal from the United States Tax Court. (Tax Ct. No. 93-26489)

Submitted: September 5, 1996 Decided: September 13, 1996

Before WIDENER and WILKINS, Circuit Judges, and PHILLIPS, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

William L. Patch, Appellant Pro Se. Gary R. Allen, Curtis Clarence Pett, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Unpublished opinions are not binding precedent in this circuit.

See Local Rule 36(c).

PER CURIAM: Appellant appeals from the tax court's decision finding a deficiency for tax year 1990. We have reviewed the record and the tax court's opinion, and find no reversible error. Accordingly, we affirm on the reasoning of the tax court. Patch v. Commissioner of the Internal Revenue Service, No. 93-26489 (Tax Ct. Feb. 21, 1996).

Additionally, we deny Appellant's motion to appoint counsel. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process.

AFFIRMED