4.2 Standard of Review

Review of cases involving a Notice of Deficiency or the determination of innocent spouse relief is de novo.1 Review of collection due process appeals is for abuse of discretion.2

• 1Porter v. Comm’r, 132 T.C. 203 (2009) (extending de novo review to § 6015(f) equitable innocent spouse relief claims).
• 2Murphy v. Comm’r, 125 T.C. 301, 307 (2005) (applying abuse of discretion standard unless underlying tax liability is at issue).