UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 98-2564

JOHN H. DOUGLAS; MARY E. DOUGLAS, Petitioners - Appellants, versus

COMMISSIONER OF INTERNAL REVENUE, Respondent - Appellee.

Appeal from the United States Tax Court. (Tax Ct. No. 96-21113)

Submitted: April 30, 1999 Decided: May 26, 1999

Before WIDENER, ERVIN, and MICHAEL, Circuit Judges.

Affirmed by unpublished per curiam opinion.

John H. Douglas, Mary E. Douglas, Appellants Pro Se. Bruce Raleigh Ellisen, Thomas James Sawyer, 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Unpublished opinions are not binding precedent in this circuit.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: John H. and Mary E. Douglas appeal from the tax court’s order determining deficiencies with respect to their 1992 and 1993 fed- eral income tax liabilities. Our review of the record and the tax court’s opinion discloses no reversible error. Accordingly, we affirm on the reasoning of the tax court. See Douglas v. Commis- sioner, No. 96-21113 (U.S. Tax Ct. Aug. 24, 1998). We dispense with oral argument because the facts and legal contentions are adequate- ly presented in the materials before the court and argument would not aid the decisional process.

AFFIRMED