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section 6653(b), and a guilty plea is equivalent to a conviction
after trial for the purpose of collateral estoppel. Plunkett v.
Commissioner, 465 F.2d 299, 305-306 (7th Cir. 1972), affg. T.C.
Memo. 1970-274; Stone v. Commissioner, 56 T.C. 213, 221-223
(1971); Arctic Ice Cream Co. v. Commissioner, 43 T.C. 68 (1964);
see, e.g., Johnson v. Sawyer, 47 F.3d 716, 722 (5th Cir. 1995);
Gray v. Commissioner, 708 F.2d 243 (6th Cir. 1983), affg. T.C.
Memo. 1981-1. A guilty plea constitutes an admission of all the
elements of the criminal charge. McCarthy v. United States, 394
U.S. 459, 466 (1969). Consequently, it is immaterial that a
conviction is based upon a guilty plea, rather than a trial on
the merits. Arctic Ice Cream Co. v. Commissioner, supra.
Petitioner claims his guilty plea was not based on conduct
in violation of section 7201. This Court has previously
indicated that it will rarely look behind the circumstances of a
guilty plea in applying the doctrine of collateral estoppel.
Stone v. Commissioner, supra at 221-223; Yarbrough Oldsmobile
Cadillac, Inc. v. Commissioner, T.C. Memo. 1993-20. If a
defendant enters an Alford (North Carolina v. Alford, 400 U.S. 25
(1970)) plea, wherein the defendant pleads guilty pursuant to a
plea agreement, but denies guilt, the collateral consequences are
triggered.
Once accepted by a court, it is the voluntary plea
of guilt itself, with its intrinsic admission of each
element of the crime, that triggers the collateral
consequences attending that plea. Those consequences
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