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involving a party to the prior litigation. * * * To
preclude parties from contesting matters that they have
had a full and fair opportunity to litigate protects
their adversaries from the expense and vexation attend-
ing multiple lawsuits, conserves judicial resources,
and fosters reliance on judicial action by minimizing
the possibility of inconsistent decisions. [Id. at
153-154; fn. ref. omitted.]
We hold that the doctrine of collateral estoppel bars Mr.
Wilson from relitigating in the instant case the matters liti-
gated in Mr. Wilson’s criminal tax proceeding, i.e., whether Mr.
Wilson underreported his income and underpaid his tax for each of
the taxable years 1993 and 1994 and whether his underpayment of
such tax for each such year was due to fraud. On the record
presented, we sustain respondent’s determinations with respect to
the respective fraud penalties under section 6663 that respondent
determined against Mr. Wilson for the taxable years 1993 and
1994.
We have considered all of Mr. Wilson’s arguments and conten-
tions that are not discussed herein, and we find them to be
without merit and/or irrelevant.
On the record presented for purposes of respondent’s motion,
we shall grant that motion.
To reflect the foregoing,
An appropriate Order will be
issued and Decision will be entered
for respondent.
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