a Determination that sustained the frivolous return penalties and federal tax lien. See Civil Penalty Notice of Determination at 1. Le Doux responded within thirty days by filing a Complaint with the Court. The United States moves the Court pursuant to rule 56 of the Federal Rules of Civil Procedure to sustain the determinations of the IRS Appeals. STANDARD OF REVIEW Section 6330 of the Internal Revenue Code does not state which standard of review courts should apply in collection due process reviews like Le Doux’, but legislative history does. A House Conference Report states courts should apply de novo review where “the validity of the tax liability [is] properly at issue.” H.R. Conf. Rep. No. 105-599, at 266 (1998). See Sego v. Commissioner, 114 T.C. 604, 610, 2000 WL 889754 (2000)(<HOLDING>). Otherwise, courts should apply abuse of
recognizing de novo standard of review holding that de novo review applies when the underlying tax liability is properly at issue holding that the proper review for the trial courts application of the law is de novo holding statutory interpretation is subject to de novo review holding that review of the construction of a sentencing statute is de novo