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
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