
    SALYER GRAIN AND MILLING COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.
    No. 86-7445.
    United States Court of Appeals, Ninth Circuit.
    Argued and Submitted April 17, 1987.
    Decided April 24, 1987.
    James E. Merritt, Washington, D.C., for petitioner-appellant.
    David Pincus, Washington, D.C., for respondent-appellee.
    Before GOODWIN, TANG and THOMPSON, Circuit Judges.
   ORDER

The decision of the Tax Court is affirmed substantially for the reasons stated by the Tax Court in its opinion in T.C.Memo. 1986-165. We do not consider the appellant’s argument concerning the tax consequences of stock options because the point was never raised in the Tax Court.  