UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 03-2130

JOHN ROLANDO TIFFANY,

Petitioner - Appellant,

versus

COMMISSIONER OF INTERNAL REVENUE,

Respondent - Appellee.

Appeal from the United States Tax Court. (Tax Ct. No. 03-2921)

Submitted: February 27, 2004 Decided: March 22, 2004

Before NIEMEYER, GREGORY, and SHEDD, Circuit Judges.

Affirmed by unpublished per curiam opinion.

John Rolando Tiffany, Appellant Pro Se. Eileen J. O’Connor, Assistant Attorney General, Bruce Raleigh Ellisen, Janet A. Bradley, 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Unpublished opinions are not binding precedent in this circuit.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 Rolando Tiffany appeals from the tax court’s orders

dismissing his petition for redetermination of his liability for

income taxes and additions to tax for the years 1997 to 2000, and

denying his motion to vacate the dismissal order. We have reviewed

the record and the tax court’s orders and find no reversible error.

Accordingly, we affirm on the reasoning of the tax court. See

Tiffany v. Comm’r of Internal Revenue, Tax Ct. No. 03-2921

(U.S.T.C. May 16, 2003 & July 16, 2003). Additionally, we deny

Tiffany’s motion for a stay of proceedings and deny the

Commissioner’s motion for sanctions. 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

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