- 14 - rejected petitioner's claim the Government improperly used a John Doe Summons). We are satisfied that no special circumstances exist which preclude the application of collateral estoppel. Because the requirements for application of collateral estoppel have been satisfied, petitioner is collaterally estopped from denying that he had gross income during 1982 through 1988 in the amounts determined by the District Court in Kersting (Consolidated Cases). Accordingly, we sustain respondent's determination of unreported income for all years. Business Expenses In various pretrial pleadings, petitioner argued generally he was entitled to offsetting deductions for bad debts and business expenditures of the nominee corporations that were not taken into account by respondent when computing the unreported income. Petitioner's interest in this issue waned by the time of trial in this case as he presented no witnesses and neither listed this as an issue nor presented any legal argument on this point on brief. 6 6 Liberally construing his brief, we glean the total of petitioner's "argument" on this point from the following six requested findings of fact: * * * * * * * 17. The corporations employed and paid attorneys to represent them and/or Henry Kersting. (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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