                                        T.C. Memo. 1997-12                                            


                                     UNITED STATES TAX COURT                                          

                               ROBERT K. LAHODNY, Petitioner v.                                       
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  


                  Docket No. 7875-93.              Filed January 7, 1997.                             


                  Robert K. Lahodny, pro se.                                                          
                  Christine V. Olsen, for respondent.                                                 



                                        MEMORANDUM OPINION                                            

                  LARO, Judge:  Respondent moves for partial summary judgment,                        
            arguing that petitioner's plea of guilty to criminal fraud under                          
            section 7201 collaterally estops him from rebutting her                                   
            determination that he is liable for civil fraud under section                             
            6653(b) for the same years.  Respondent supports her motion with

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