
    Harvey WALDMAN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.
    No. 87-7417.
    United States Court of Appeals, Ninth Circuit.
    Argued and Submitted May 3, 1988.
    Decided July 5, 1988.
    Timothy S. Hams, Los Angeles, Cal., for petitioner-appellant.
    Kenneth L. Greene, Dept, of Justice, Washington, D.C., for respondent-appellee.
    Before GOODWIN and HALL, Circuit Judges, and BELLONI, District Judge.
    
      
       The Honorable Robert C. Belloni, Senior United States District Judge, District of Oregon, sitting by designation.
    
   ORDER

We affirm the judgment substantially for the reasons stated by the Tax Court in its opinion in 88 T.C. 1384 (1987).  