
    Brian HOLLAND, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 86-7444.
    United States Court of Appeals, Ninth Circuit.
    Argued and Submitted Sept. 9, 1987.
    Decided Sept. 21, 1987.
    Hallison H. Young, Detroit, Mich., for petitioner.
    Michael L. Paup, David English Car-mack, and Joan I. Oppenheimer, Washington, D.C., for respondent.
    Before HALL, NOONAN and THOMPSON, Circuit Judges.
   ORDER

The judgment is affirmed on the basis of the opinion of Judge Meade Whitaker. Brian Holland, 51 T.C.M. 164 (1985); ¶ 85,625 P-H Memo TC.  