Harold Stanley appeals the tax court’s 1 adverse grant of summary judgment in his tax action. After careful consideration, see Nestle Purina Petcare Co. v. Comm’r, 594 F.3d 968, 970 (8th Cir.) (de novo review), cert. denied — U.S. -, 131 S.Ct. 86, 178 L.Ed.2d 241 (2010), we conclude summary judgment was proper, see Bell v. Comm’r, 126 T.C. 356, 358 (2006) (26 U.S.C. § 6330 allows challenges to existence or amount of underlying liability if petitioner did not receive notice of deficiency or otherwise have opportunity to dispute liability; this statutory preclusion is triggered by opportunity to contest underlying liability, even if opportunity is not pursued). We therefore affirm the ruling of the tax court. See 8th Cir. R. 47B. We deny appellant’s pending motion.