- 14 - The two convictions, however, do not collaterally estop him from denying intent to evade his own tax liability. Petitioner’s sophistication as a lawyer and investor may tend to show that he had such intent, but here, unlike the taxpayer in Considine, petitioner has made a showing in opposition to respondent's motion, and the issue of intent is a triable issue of fact. We therefore deny respondent’s motion for summary judgment. For the preceding reasons, An order will be issued denying respondent’s motion for summary judgment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
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