Robert Morgan appeals after the tax court issued a decision denying his motion to dismiss for lack of jurisdiction and upholding a determination by the Commissioner of Internal Revenue that he was hable for an income tax deficiency and penalties. After careful review of the record, we conclude that the tax court’s decision was proper. See Campbell v. Comm’r, 164 F.3d 1140, 1142 (8th Cir. 1999) (standards of review). Accordingly, we affirm. See 8th Cir. R. 47B.