Cir

MEMORANDUM

Marc Pretscher appeals pro se from the Tax Court’s summary judgment allowing the Commissioner of Internal Revenue (“Commissioner”) to proceed with its collection action. We have jurisdiction under 26 U.S.C. § 7482 (a)(1). We review de novo. Miller v. Comm’r, 310 F.3d 640, 642 (9th Cir.2002). We affirm.

The Tax Court properly granted summary judgment for the Commissioner because Pretscher failed to raise a genuine dispute of material fact as to whether the proposed collection action for tax years 2001 through 2004 should not proceed. See Hansen v. United States, 7 F.3d 137, 138 (9th Cir.1993) (per curiam); Hughes v. United States, 953 F.2d 531, 535 (9th Cir.1992).

Pretscher’s contention that he was improperly denied a face-to-face collection due process hearing is unavailing because “[a] CDP hearing may, but is not required to, consist of a face-to-face meeting....” 26 C.F.R. § 301.6330 -l(d)(2) (Q & A-6).

The record does not support Pretscher’s contention that the Tax Court considered evidence outside the administrative record.

Pretscher’s remaining contentions are unpersuasive.

AFFIRMED.

This disposition is not appropriate for publication and is not precedent…