Wayne Curtis Siron appeals from the tax court’s order upholding the Commissioner’s determination of a deficiency in Siron’s 1998 income taxes and assessing penalties. We have reviewed the record and the tax court’s opinion and find no reversible error. Accordingly, we affirm on the reasoning of the tax court. Siron v. *528 Comm’r., Tax Ct. No. 11208-04, 2006 WL 859174 (U.S. Tax Ct. Apr. 4, 2006). 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.