17 F.3d 398
73 A.F.T.R.2d 94-1100
Eugene H. WHITEHEAD and Theresa H. Whitehead, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
No. 92-70571.
United States Court of Appeals, Ninth Circuit.
Argued and Submitted Jan. 4, 1994.
Decided Jan. 20, 1994.
NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel.
ORDER**
The decision of the tax court is AFFIRMED for the reasons set forth in the tax court memorandum decision filed September 19, 1991.