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).
