Jeffrey Michael Steingold appeals from the tax court’s order determining a deficiency and penalty with respect to his 1994 federal income tax liability. 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. Steingold v. Commissioner, No. 98-19841 (U.S. Tax Ct. Dec. 15, 2000). 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.