
    Jack FREEMAN; Janet Freeman, Petitioners — Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent— Appellee.
    No. 02-70006.
    IRS No. 13195-99.
    United States Court of Appeals, Ninth Circuit.
    Argued and Submitted Feb. 14, 2003.
    Decided March 5, 2003.
    Before BEEZER, THOMAS and CLIFTON, Circuit Judges.
   MEMORANDUM

The judgment of the United States Tax Court is affirmed for the reasons stated by Judge Whalen in his memorandum opinion dated September 28, 2001. 
      
       This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as may be provided by Ninth Circuit Rule 36-3.
     