UNITED STATES COURT OF APPEALS

TENTH CIRCUIT

JOHN W. CONNELLY and PHYLLIS M. CONNELLY,

Petitioners - Appellants,

v.

COMMISSIONER OF INTERNAL REVENUE,

Respondent - Appellee.

WILLIAM A. JACOBS and ANN M. JACOBS,

Petitioners - Appellants,

v.

COMMISSIONER OF INTERNAL REVENUE,

Respondent - Appellee.

No. 00-9011

(U.S. Tx.Ct.)

(T.C.No. 627-98)

No. 00-9012

(U.S. Tx.Ct.)

(T.C. No. 626-98)

ORDER AND JUDGMENT*

Before MURPHY, HALL**, and PORFILIO, Circuit Judges.

After reviewing the briefs of the parties and the record below, and having had the benefit of oral argument, we conclude that the tax court did not err. We therefore affirm the judgment of the tax court on the basis of that court's opinion.

Entered for the Court

Cynthia Holcomb Hall

Circuit Judge