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.
Page: 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011