T.C. Memo. 1997-133
UNITED STATES TAX COURT
HAROLD WAPNICK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 269-94. Filed March 13, 1997.
Harold Wapnick, pro se.
Monica E. Koch, for respondent.
MEMORANDUM OPINION
GALE, Judge: This matter is presently before the Court on
respondent's motion for partial summary judgment, in which
respondent argues that the conviction of Harold Wapnick
(petitioner) under section 72011 collaterally estops him from
disputing that there is an underpayment of income tax, and that
1 Section references are to the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
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