John S. Fagan - Page 6

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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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