Jeff R. Taylor - Page 1

                                 T.C. Memo. 1997-82                                   

                               UNITED STATES TAX COURT                                

                            JEFF R. TAYLOR, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8493-96.              Filed February 18, 1997.              

               John C. Meaney, for petitioner.                                        
               Shirley M. Francis, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               PARR, Judge:  Respondent moves for partial summary judgment            
          under Rule 121,1 arguing that petitioner's plea of guilty to                
          criminal fraud under section 7201 collaterally estops him from              

          1    All section references are to the Internal Revenue Code in             
          effect for the taxable year in issue, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure, unless                    
          otherwise indicated.  All dollar amounts are rounded to the                 
          nearest dollar.                                                             

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