With no explanation, chose the best option from "A", "B", "C" or "D". 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

A: holding that the taxpayer filed a frivolous return because it had no basis in law or fact
B: 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
C: 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
D: holding return filled with zeros despite w2 showing considerable income was substantially incorrect or frivolous
D.