Willis

MEMORANDUM **

Alice Willis 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 pursuant to 26 U.S.C. § 7482 (a). We review de novo the Tax Court’s grant of summary judgment, Miller v. Comm’r, 310 F.3d 640, 642 (9th Cir.2002), and we affirm.

The Tax Court properly granted the Commissioner’s summary judgment motion because Willis failed to raise any genuine issue of material fact and the record supports the Commissioner’s determination that the collection actions should proceed. See Hansen v. United States, 7 F.3d 137, 138 (9th Cir.1993) (per curiam) (affirming summary judgment where Commissioner’s evidence supported its assessments and taxpayers relied upon concluso-ry allegations unsupported by facts).

The record does not support Willis’s contentions that the Tax Court improperly *291 conducted a de novo trial and considered evidence outside the administrative record.

Willis’s contention that she was improperly denied a face-to-face collection due process (“CDP”) hearing is unavailing because “[a] CDP hearing may, but is not required to, consist of a…