Assuming, without deciding, that a de novo standard of review applies, the Court will uphold IRS Appeals’ decisions. And because IRS Appeals did not make a legal error, it also did not abuse its discretion II. LE DOUX’ 1997 AND 1998 INDIVIDUAL INCOME TAX RETURNS ARE FRIVOLOUS UNDER 26 U.S.C. § 6702. Income tax returns are frivolous under § 6702 if there is: (i) a purported return; (ii) a failure to provide information upon which the IRS can judge the return’s correctness; and (iii) a frivolous position or desire to impede tax administration. See Bradley v. United States, 817 F.2d at 1402; Davis v. United States Government, 742 F.2d 093 (W.D.Wash.2002) (noting return filled with zeros does not contain sufficient information); Lemieux v. United States, 230 F.Supp.2d at 1146 (D.Nev.2002) (<HOLDING>). Le Doux’ return was based on a frivolous
holding as frivolous taxpayers argument that he was not subject to the income tax because he is a non resident alien and awarding sanctions of 8000 holding that the statement of current monthly income was the presumptive amount of projected disposable income but presumption could be rebutted by the debt or upon a showing of substantial change of circumstances holding return filled with zeros despite w2 showing considerable income was substantially incorrect or frivolous holding that the taxpayer filed a frivolous return because it had no basis in law or fact holding that wages are subject to oregons personal income tax and that a taxpayers argument to the contrary was frivolous