M.J. Wood Associates, Inc. - Page 1

                                        T.C. Memo. 1998-375                                             

                                     UNITED STATES TAX COURT                                            

                          M.J. WOOD ASSOCIATES, INC., Petitioner v.                                     
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   
                             LONNIE C. CHRISTENSEN, Petitioner v.                                       
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                    

                  Docket Nos. 10978-94, 11982-94.      Filed October 15, 1998.                          

                        Ps timely filed petitions with the Tax Court.                                   
                  Subsequently, Ps became defendants in a criminal tax                                  
                  case before the U.S. District Court for the District of                               
                  Nevada.  In the criminal tax case, Ps were ordered to                                 
                  pay fines and make restitution of a total amount of                                   
                  civil tax liability to the Internal Revenue Service for                               
                  tax years 1972 through 1993 (which include the tax                                    
                  years in issue in this civil tax case).  Ps moved for                                 
                  summary judgment here, arguing that the doctrines of                                  
                  res judicata and collateral estoppel obviate the need                                 
                  for this Court to consider R's deficiency                                             
                  determinations.  Ps further argue that the District                                   
                  Court's criminal case restitution orders constitute                                   
                  adjudications of the amounts of tax, interest, and                                    
                  penalties owed by Ps.  R contends that Ps are not                                     
                  entitled to summary judgment because jurisdiction to                                  

Page:   1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011