What is the standard of review for a tax court's determinations of law de novo and its findings of fact?
MultiRegion, United States of America
The following excerpt is from Chavez v. C.I.R., 978 F.2d 714 (9th Cir. 1992):
We review the tax court's determinations 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 that for a civil bench trial in district court). The tax court's imposition of a penalty under 26 U.S.C. 6673 is reviewed for an abuse of discretion. Id. at 1454.
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