Pate v. Commissioner of Internal Revenue

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT United States Court of Appeals Fifth Circuit FILED January 31, 2008 No. 07-60731 Summary Calendar Charles R. Fulbruge III Clerk RICHARD N PATE Petitioner-Appellant v. COMMISSIONER OF INTERNAL REVENUE Respondent-Appellee Appeal from a Decision of the United States Tax Court No. 13649-06L 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 R. 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5TH CIR.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.