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at 121, we believe that the 1989 net worth computation is so
unreliable as to negate any presumption of correctness. As in
Jacobs v. Commissioner, supra, with regard to taxable year 1989,
respondent has failed to “show the correct amount of petitioner’s
reconstructed taxable income or [to] provide any basis for
estimating it.” See also Gallo v. Commissioner, T.C. Memo. 1983-
367. Accordingly, this issue is decided for petitioner husband.
Respondent’s 1990 Income Reconstruction for Petitioners
For taxable year 1990, by his criminal plea petitioner
husband explicitly admitted that he had unreported income of
$63,610, as determined by respondent’s 1990 criminal net worth
calculation, which was predicated on an opening net worth of
$4,845. Petitioner did not appear at trial to refute his prior
admission. Cf. Toushin v. Commissioner, T.C. Memo. 1999-171.
Petitioner husband’s admission is strong evidence of the
validity of the 1990 criminal net worth computation, and
consequently of the 1990 civil net worth computation, which was
derived directly therefrom. Petitioner husband’s admission in
the criminal proceeding does not collaterally estop him, however,
from challenging the specific deficiency amount in this
proceeding, because “the determination of an exact liability was
not essential to the judgment, a prerequisite to the application
of the doctrine of collateral estoppel.” Moore v. United States,
360 F.2d 353, 356 (4th Cir. 1965) (internal quotation marks
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