Court of Appeals for the Third Circuit September 15, 2009, No. 09-1111 (Freeland v. Commissioner)

OPINION

PER CURIAM.

Frank Freeland appeals pro se from the United States Tax Court’s Order and Decision granting the Commissioner of Internal Revenue’s (IRS) motion for summary judgment in this action to collect unpaid taxes. We will affirm.

I.

On March 30, 2007, following a Collection Due Process hearing (26 U.S.C.