Tibor and Christel Horwath appeal from the tax court’s order upholding the Commissioner’s assessment of deficiencies and accuracy-related penalties with respect to their 1997 and 1998 federal income tax liability. Our review of the record and the tax court’s opinion discloses no reversible error. Accordingly, we affirm for the rea *467 sons stated by the tax court. See Horwath v. Comm’r, IRS, No. 02-16927 (U.S. Tax Ct. Sept. 21, 2004). 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