- 12 - Biaggi v. Commissioner, T.C. Memo. 2000-48, affd. 8 Fed. Appx. 66 (2001); Wilson v. Commissioner, T.C. Memo. 1994-454; Avery v. Commissioner, supra; Williamson v. Commissioner, T.C. Memo. 1993-246. Petitioner has failed to submit credible evidence that he knowingly filed the false returns for any reason other than to evade taxes he knew to be owing. Thus, we conclude that petitioner fraudulently intended to underpay his tax for each of the years at issue. Further, petitioner has failed to submit credible evidence showing that any part of the underpayment attributable to the omitted income is not due to fraud. To the contrary, the record establishes by clear and convincing evidence that the entire underpayment for each year is due to fraud. Accordingly, we hold that petitioner is liable for the section 6663 civil fraud penalty on the entire underpayment for each year at issue. Sec. 6663(b). Issue 2. Whether the Doctrines of Res Judicata, Collateral Estoppel, and/or Double Jeopardy Bar Assessment of Deficiencies and Interest for All of the Years at Issue in an Amount Greater Than $61,700 Petitioner asserts that the doctrines of res judicata, collateral estoppel, and/or double jeopardy preclude retrial of, or estop respondent with respect to, the liabilities before this Court. We disagree.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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