the assessment of the accuracy-related penalties. Appellants now appeal from the Tax Court’s decision. DISCUSSION “Congress directed the United States Courts of Appeals to review tax court decisions ‘in the same manner and to the same extent as decisions of the district courts in civil actions tried without a jury.’ ” Love Box Co., Inc. v. Comm’r, 842 F.2d 1213, 1215 (10th Cir. 1988) (quoting 26 U.S.C. § 7482(a)(1)). Accordingly, we review factual questions for clear error and legal questions de novo. Id. Recognizing that the deductibility of educational expenses is a mixed question of fact and law in which factual issues predominate, we have reviewed that determination for clear error. See id. at 1215-16; see also Glasgow v. Comm’r, 486 F.2d 1045, 1046 (10th Cir. 1973) (per curiam) (<HOLDING>). I. Theories Not Listed in the Notice of
holding that generally the question of waiver and estoppel is a question of fact holding that estoppel was a question of fact holding the question of whether insurance companys requests were reasonable under policy language was a fact question holding it is a question of fact holding that whether educational expenses were deductible was essentially a question of fact