UNITED STATES COURT OF APPEALS For the Fifth Circuit

No. 00-30573 Summary Calendar

DUDLEY JOSEPH CALLAHAN; MYRNA DUPUY CALLAHAN, Plaintiffs-Appellants,

VERSUS

COMMISSIONER OF INTERNAL REVENUE,

Defendant-Appellee.

Appeal from the United States District Court For the Middle District of Louisiana 99-CV-295 May 17, 2001 Before DAVIS, JONES and DeMOSS, Circuit Judges.

PER CURIAM:* For reasons assigned by the district court in its April 10, 2000 Order and Reasons, the judgment of the court is AFFIRMED.

* Pursuant to 5TH CIR. R. 47.5, the Court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5TH CIR. R. 47.5.4.