Duane E. Hudspath appeals from the tax court’s order granting summary judgment in favor of the Commissioner in the underlying collection proceeding regarding Hudspath’s 1996 and 1997 federal income tax liabilities. Our review of the record and the tax court’s opinion discloses no reversible error. Accordingly, we affirm for the reasons stated by the tax court. See Hudspath v. Comm’r, No. 04-5865-L (U.S. Tax Ct. Apr. 12, 2005). 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.