UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 99-1984 CHARLES RAY WATERS, Petitioner - Appellant, versus COMMISSIONER OF INTERNAL REVENUE, Respondent - Appellee. Appeal from the United States Tax Court. (Tax Ct. No. 97-23924) Submitted: October 21, 1999 Decided: October 26, 1999 Before WIDENER and TRAXLER, Circuit Judges, and BUTZNER, Senior Circuit Judge. Dismissed by unpublished per curiam opinion. Charles Ray Waters, Appellant Pro Se. Jonathan Samuel Cohen, Jeffrey Ronald Meyer, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. Unpublished opinions are not binding precedent in this circuit. See Local Rule 36(c). PER CURIAM: Charles Ray Waters appeals from the tax court’s order deter- mining deficiencies and penalties with respect to his 1987 through 1994 federal income tax liability. Our review of the record dis- closes no reversible error. The Commissioner established that Waters willfully failed to file tax returns or pay estimated taxes for the years at issue. Moreover, we find no abuse of discretion in the tax court’s decision to impose sanctions under 26 U.S.C. § 6673 (1994). Accordingly, we deny Waters’ motion to proceed in forma pauperis and dismiss the appeal. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process. DISMISSED 2