UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 96-2445

JOSEPH FRANCIS CUNNINGHAM, Petitioner - Appellant, versus COMMISSIONER OF INTERNAL REVENUE, Respondent - Appellee.

On Appeal from the United States Tax Court. (Tax Ct. No. 93-22176)

Submitted: April 1, 1997 Decided: April 9, 1997

Before MURNAGHAN, ERVIN, and WILLIAMS, Circuit Judges.

Affirmed by unpublished per curiam opinion.

Joseph Francis Cunningham, Appellant Pro Se. Sara Ann Ketchum, 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Unpublished opinions are not binding precedent in this circuit.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 the tax court's order finding deficiencies in tax year 1987, 1988, and 1989. 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. Cunningham v. Commis- sioner, No. 93-22176 (Tax Ct. Aug. 15, 1996). 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