Whether a court of appeals may reverse a fact-dependent ruling of the tax court without articulating any standard of review, finding that any of the tax court's factual findings were clearly erroneous, identifying which of the tax court's detailed factual findings with which it disagreed, and identifying facts it relied upon in deciding another issue that the tax court had never reached.

Whether a court of appeals may reverse a fact-dependent ruling of the tax court without articulating any standard of review, finding that any of the tax court's factual findings were clearly erroneous, identifying which of the tax court's detailed factual findings with which it disagreed, and identifying facts it relied upon in deciding another issue that the tax court had never reached