[NOT FOR PUBLICATION NOT TO BE CITED AS PRECEDENT]

                 United States Court of Appeals

                     For the First Circuit











No. 98-1620



                      WILLIAM HENRY SUNDEL,



                      Petitioner, Appellant,



                                v.



                COMMISSIONER OF INTERNAL REVENUE,



                      Respondent, Appellee.







             APPEAL FROM THE UNITED STATES TAX COURT

                                

                                

                                

                                

                             Before

                                

                      Lynch, Circuit Judge,

                 Bownes, Senior Circuit Judge,

                   and Lipez, Circuit Judge.

                                

                                

                                

                                

     William H. Sundel on brief pro se.

     Loretta C. Argrett, Assistant Attorney General, Teresa E.

McLaughlin and Robert J. Branman, Attorneys, Tax Division,

Department of Justice, on brief for appellee.











June 29, 1999







                                

                                

                                

                                

                                

                                



     Per Curiam.  We have reviewed the record in this case,

including the briefs of the parties.  We affirm the decision of the

United States Tax Court, essentially for the reasons given by the

court in its memorandum findings of fact and opinion.  Sundel v.

Commissioner, 75 T.C.M. 1853 (1998).  Any further points raised by

petitioner in his brief to this court are without merit.

     Affirmed.