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1983 and 1985 subscribed under penalties of perjury. Those
convictions do not collaterally estop him from challenging
respondent’s allegations of civil fraud. Nevertheless, those
convictions create powerful inferences that petitioner possessed
the willfulness necessary to satisfy the intent element of
section 6653(b)(1). See Wilson v. Commissioner, T.C. Memo. 1994-
454; Avery v. Commissioner, T.C. Memo. 1993-344; Estate of
Sawczak v. Commissioner, T.C. Memo. 1993-210, affd. 46 F.3d 70
(11th Cir. 1995).
In addition to those inferences, petitioner is collaterally
estopped from denying the following facts established in his
criminal trial: The Wedtech shares were paid to petitioner as a
bribe to influence him to use the power of his office to secure
Government contracts for Wedtech. The Wedtech shares were paid
to him in response to extortionate demands by him. Petitioner
knew that, if the shares were received by him in his own name,
his income for 1983 would exceed the statutory cap on income
provided for under rules of the U.S. House of Representatives.
For that reason, petitioner agreed to have the Wedtech shares
registered in the name of Richard. When the Wedtech shares were
issued, petitioner knew that, under the circumstances, he was the
owner of those shares, that Richard was not, and that Richard
received those shares as a nominee for petitioner. When the
Wedtech shares were issued, petitioner knew that, as owner of
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