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Once accepted by the District Court, petitioner’s voluntary plea
of guilt for violation of section 7201, with its intrinsic
admission of each element of the crime, triggered the related
consequences attending such plea, including collateral estoppel
as to fraud under section 6653(b). Blohm v. Commissioner, 994
F.2d 1542, 1554 (11th Cir. 1993), affg. T.C. Memo. 1991-636.
Nothing petitioner has raised changes the conclusive facts that
he pleaded guilty and was found criminally guilty of violating
section 7201 by engaging in income tax evasion.
Based on the cited authorities, petitioner is collaterally
estopped from denying that some part of the underpayment in his
tax was due to fraud within the meaning of section 6653(b).
An appropriate order will
be issued.
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Last modified: May 25, 2011