UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 98-1376

RONALD E. REED, Petitioner - Appellant, versus

COMMISSIONER OF INTERNAL REVENUE, Respondent - Appellee.

Appeal from the United States Tax Court. (Tax Ct. No. 91-29376)

Submitted: July 2, 1998 Decided: July 21, 1998

Before NIEMEYER and HAMILTON, Circuit Judges, and HALL, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

Ronald E. Reed, Appellant Pro Se. John A. Dudeck, Jr., 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Unpublished opinions are not binding precedent in this circuit.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: Ronald E. Reed appeals from the tax court’s decision deter- mining a deficiency and penalties with respect to his 1985, 1986, and 1987 federal income tax liability and from the denial of his motion for reconsideration. Our review of the record and the tax court’s decision discloses no reversible error and no abuse of dis- cretion. Accordingly, we affirm on the reasoning of the tax court.

Reed v. Commissioner of Internal Revenue, Tax Ct. No. 91-29376 (U.S.T.C. Dec. 4, 1997). We dispense with oral argument because the facts and legal contentions are adequately presented in the mate- rials before the court and argument would not aid the decisional process.

AFFIRMED