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.Page: 1 2 3 4 5 6 7 8 Next
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