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the prior litigation. See Peck v. Commissioner, 90 T.C. 162,
166-167 (1988), affd. 904 F.2d 525 (9th Cir. 1990).
On the basis of the record, we find that all five conditions
have been satisfied in the instant case, and, pursuant to the
doctrine of collateral estoppel, find that the holding in
Rambacher I is controlling here. We therefore hold that
petitioners are liable for the additions to tax pursuant to
sections 6653(a)(1) and (2) for the 1983 taxable year.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011