- 6 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011