James E. Merritt, Washington, D.C., for petitioner-appellant.
David Pincus, Washington, D.C., for respondent-appellee.
Appeal from a Decision of the United States Tax Court.
Before GOODWIN, TANG and THOMPSON, Circuit Judges.
ORDER
1
The decision of the Tax Court is affirmed substantially for the reasons stated by the Tax Court in its opinion in T.C.Memo. 1986-165. We do not consider the appellant's argument concerning the tax consequences of stock options because the point was never raised in the Tax Court.
