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Before KELLY, McKAY, and BRISCOE, Circuit Judges.

In this tax case arising under the Internal Revenue Code, Lindsey K. Springer appeals the Order and Decision entered by the United States Tax Court granting summary judgment in favor of the Commissioner of Internal Revenue on Mr. Springer’s challenges to collection due process determinations issued by the Internal Revenue Service’s Office of Appeals. The determinations permit the IRS to proceed to collect by levy Mr. Springer’s delinquent federal income tax liabilities for 1990 through 1995 and a penalty imposed by the Tax Court in 1996 under 26 U.S.C. § 6673(a)(1) in a prior proceeding. Exercising jurisdiction under 26 U.S.C. § 7482(a)(1), and having reviewed the Tax Court’s grant of summary judgment de novo, see Scanlon White, Inc. v. Comm’r, 472 F.3d 1173, 1174 (10th Cir. 2006), we affirm.

 
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