Clifford Miller appeals from the tax court’s order granting summary judgment to the Commissioner on Miller’s action challenging the underlying collection activity. Our review of the record and the tax court’s opinion discloses no reversible error. Accordingly, we affirm on the reasoning of the tax court. Miller v. Commissioner, Tax Ct. No. 99-10563, 2000 WL 1868089 (U.S. Tax Ct. Dec. 21, 2000). 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.

AFFIRMED.