Court of Appeals for the Fifth Circuit July 3, 2003, No. 02-60565 (Rayner v. Commissioner)

PER CURIAM*

Drew Allen Rayner pro se appeals the United States Tax Court’s grant of summary judgment for the Commissioner of *740Revenue and accompanying order that he pay an income tax deficiency of $89,388 for tax year 1998; an additional tax of $3546 pursuant to 26 U.S.C. § 6654 for failure to pay estimated tax; and a penalty of $5000 pursuant to 26 U.S.C.