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1981-1; Brooks v. Commissioner, 82 T.C. 413, 431 (1984), affd.
without published opinion 772 F.2d 910 (9th Cir. 1985); Amos v.
Commissioner, 43 T.C. 50 (1964), affd. 360 F.2d 358 (4th Cir.
1965). Moreover, it is generally assumed that a guilty plea is
made voluntarily. Huff v. Commissioner, T.C. Memo. 1988-564.
In the case at bar, it is uncontroverted that the
petitioner, a college graduate with several years of experience
in business, who was represented by counsel, pleaded guilty to a
charge of tax evasion, under section 7201 for 1987. Petitioner
asserts, however, that the Supreme Court, in Montana v. United
States, 440 U.S. 147, 155, (1979), expressly states that prior to
invoking collateral estoppel, a court should inquire into any
special circumstances which would warrant "an exception to the
normal rules of issue preclusion". It is petitioner's position
that his allegedly coerced and involuntary plea of guilty to
fraud for 1987 is such an exceptional circumstance. We disagree.
Petitioner raised the issue of coercion on appeal and failed
to persuade the Court of Appeals, which affirmed his conviction,
and the Supreme Court denied review. The judgment in his
criminal case is final. We caution petitioner's counsel that his
objection to respondent's motion borders on the behavior
proscribed by section 6673(a)(2)(A) (in regard to multiplying the
proceedings unreasonably) and Rule 33(b) (in regard to signing a
pleading not well grounded in fact nor warranted by existing law,
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