
    Richard N. PATE, Petitioner-Appellant v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
    No. 07-60731
    Summary Calendar.
    United States Court of Appeals, Fifth Circuit.
    Jan. 31, 2008.
    Richard N. Pate, Justin, TX, pro se.
    Robert R. Di Trolio, U.S. Tax Court, Donald L. Korb, Chief Counsel, Internal Revenue Service, Laurie Allyn Snyder, Eileen J. O’Connor, U.S. Department of Justice, Washington, DC, for Respondeni>-Appellee.
    Before REAVLEY, SMITH, and BARKSDALE, Circuit Judges.
   PER CURIAM:

The order of the Tax Court is affirmed. No arguments of appellant have arguable merit. The reasons for the ruling have been fully explained to appellant by Judge Thornton’s opinion of May 29, 2007 and by the brief of the Commissioner of Internal Revenue.

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       Pursuant to 5th Cir. R. 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Cir. R. 47.5.4.
     