William ZEPEDA, Petitioner-Appellant, v. COMMISSIONER of INTERNAL REVENUE, RespondentAppellee, 623 F. App'x 484

MEMORANDUM William Zepeda appeals pro se from the Tax Court’s order and decision granting the Commissioner’s motion for entry of decision regarding a federal tax lien. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review de novo. Charlotte’s Office Boutique, Inc. v. Comm’r, 425 F.3d 1203, 1211 (9th Cir.2005). We affirm. The Tax Court properly granted the Commissioner’s motion for entry of deeision, sustaining in part a federal tax lien regarding tax liability for the years 2005 and 2006, because Zepeda failed to raise the underlying tax liability in a collection due process (“CDP”) hearing.

See Treas. - Reg. § 301.6330-1(0(2) Q & A F3 (when a taxpayer disagrees with a notice of determination, the taxpayer may ask the Tax Court to consider the issues that were properly raised in the CDP hearing); Gia-melli v. Comm’r, 129 T.C. 107, 115 (2007) (Tax Court does not have authority to consider challenges to underlying tax liability that were not properly raised before the appeals office). We reject Zepeda’s contentions that the Tax Court erred by sustaining the notice of determination or improperly denied him a trial. The Commissioner’s motion for an exemption, filed October 19, 2015, is granted. AFFIRMED.

This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3.