UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 17-1654 JOSEPH CORNELIUS RUDDY, JR.; JOANNE C. RUDDY, Petitioners - Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent - Appellee. Appeal from the United States Tax Court. (Tax Ct. No. 14602-15L) Submitted: June 21, 2018 Decided: June 25, 2018 Before DIAZ and HARRIS, Circuit Judges, and SHEDD, Senior Circuit Judge. Affirmed by unpublished per curiam opinion. Joseph Cornelius Ruddy, Jr., Joanne C. Ruddy, Appellants Pro Se. Robert Joel Branman, Melissa Briggs, Joan Iris Oppenheimer, Tax Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. Unpublished opinions are not binding precedent in this circuit. PER CURIAM: Joanne C. Ruddy and Joseph Cornelius Ruddy, Jr., appeal the tax court’s order granting summary judgment in favor of the Commissioner on their petition seeking review of the Commissioner’s notice of determination with respect to collection of their 2009 federal income tax liability. We have reviewed the record and find no reversible error. Accordingly, we affirm for the reasons stated by the tax court. Ruddy v. Comm’r, Tax Ct. No. 14602-15L (U.S. Tax Ct. Feb. 22, 2017). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process. AFFIRMED 2