Vicki S. Pless and Coy E. Pless appeal from the tax court’s orders upholding the notice of federal tax lien with respect to the Plesses’ 1998 income tax liability and upholding the Commissioner’s determination that Vicki Pless was not entitled to relief from joint and several liability. We have reviewed the record and the tax court’s memorandum and opinions and find no abuse of discretion and no reversible error. Accordingly, we affirm for the rea *179 sons stated by the tax court. See Pless v. Comm’r of Internal Revenue, No. 03-1917 (U.S. Tax Ct. Feb. 3, 10 & 19, 2004). 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