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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