The following excerpt is from Rust v. C.I.R., 974 F.2d 1343 (9th Cir. 1992):
We review the tax court's determination of law de novo and its findings of fact for clear error. See Grimes v. Commissioner, 806 F.2d 1451, 1453 (9th Cir.1986) (standard of review for a tax court decision is the same as review of a civil bench trial in district court). The tax court's imposition of sanctions pursuant to 26 U.S.C. 6673 is reviewed for an abuse of discretion. Id. at 1454.
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