Peter Goldberger, Ardmore, Pa., for Appellant.
Michelle B. O'Connor, Tax Div., U.S. Dep't of Justice, Washington, D.C., for Appellee.

Before KEARSE, MINER and McLAUGHLIN, Circuit Judges.

*1 Appeal from the United States District Court for the District of Connecticut.

This cause came on to be heard on the record from the United States District Court for the District of Connecticut, and was argued by counsel.

ON CONSIDERATION WHEREOF, it is now hereby ordered, adjudged, and decreed that the judgment of said District Court be and it hereby is affirmed on the authority of Browne v. United States, No. 98-6124, 1999 WL 304399 (2d Cir. Mar. 24, 1999), slip op. 3499 (opinion filed May 14, 1999), and Adams v. Commissioner of Internal Revenue, 170 F.3d 173 (3d Cir. 1999), which are not meaningfully distinguishable from the present case.

We have considered all of plaintiff's contentions on this appeal and have found them to be without merit. The judgment of the district court is affirmed.

FOR THE COURT:
KAREN GREVE MILTON, Acting Clerk
by:
\s\ Lucille Carr______

¹ THIS SUMMARY ORDER WILL NOT BE PUBLISHED IN THE FEDERAL REPORTER AND MAY NOT BE CITED AS PRECEDENTIAL AUTHORITY TO THIS OR ANY OTHER COURT, BUT MAY BE CALLED TO THE ATTENTION OF THIS OR ANY OTHER COURT IN A SUBSEQUENT STAGE OF THIS CASE, IN A RELATED CASE, OR IN ANY CASE FOR PURPOSES OF COLLATERAL ESTOPPEL OR RES JUDICATA.