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collateral estoppel is not satisfied. We therefore find that
respondent is not collaterally estopped from asserting tax
deficiencies for the 1986 through 1988 tax years.
B. Respondent's Deficiency Determination
Respondent determined that petitioner underpaid his 1986
through 1988 income tax by $10,690, $17,884, and $19,350,
respectively. The underpayment is attributable to petitioner's
failure to file his income tax returns for 1986 through 1988, and
report income earned in his capacity as a self-employed
independent contractor. Petitioner does not argue that
respondent's determination of the deficiency is incorrect. We
therefore sustain respondent's determination.
II. Res Judicata and The Additions To Tax
As an initial matter, petitioner argues that the doctrine of
res judicata bars respondent from litigating petitioner's
liability for any additions to tax. Petitioner contends that the
Government's failure to raise the issue of any additions to tax
in the criminal proceeding precludes respondent from raising the
issue before this Court.
Res judicata (claim preclusion) precludes relitigation of
issues that were or could have been raised regarding a cause of
action. Commissioner v. Sunnen, 333 U.S. 591 (1948). Under the
doctrine of res judicata, when a court of competent jurisdiction
has entered a final judgment on the merits of a cause of action,
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