The following excerpt is from Stengel v. C.I.R., 996 F.2d 1227 (9th Cir. 1993):
In reviewing the tax court's decision to uphold the Commissioner's determination of deficiencies, we review the tax court's conclusions of law de novo and findings of fact for clear error. Betson v. Commissioner, 802 F.2d 365, 367 (9th Cir.1986).
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