The following excerpt is from National Life Ins. Co. v. C.I.R., 103 F.3d 5 (2nd Cir. 1996):
We review the tax court's determinations of fact for clear error and its determinations of law, including its interpretation of federal statutes, de novo. Estate of Herrmann v. Commissioner, 85 F.3d 1032, 1035 (2d Cir.1996).
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