United States Court of Appeals FOR THE EIGHTH CIRCUIT ___________

No. 02-3734 ___________

Stephen and Sara Galligan, * * Appellants, * Appeal from the United States * Tax Court. v. * * [UNPUBLISHED] Commissioner of Internal Revenue, * * Appellee. * ___________

Submitted: April 4, 2003

Filed: April 15, 2003 ___________

Before MELLOY, FAGG, and SMITH, Circuit Judges. ___________

PER CURIAM.

Stephen and Sara Galligan appeal from the tax court's adverse judgment, following a trial, in their action contesting the assessment of deficiencies in their federal income taxes for tax years 1996 and 1997. Having carefully reviewed the record, we conclude the judgment was proper for the reasons explained by the tax court. Accordingly, we affirm. See 8th Cir. R. 47B. A true copy.

Attest:

CLERK, U.S. COURT OF APPEALS, EIGHTH CIRCUIT.

-2-