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6. Conclusion
The Court concludes that collateral estoppel bars petitioner
from relitigating the issue of whether his 1999 Federal income
tax return was improperly selected for audit in violation of
sections 6103 and 7605(b) and petitioner’s constitutional rights.
The District Court previously found that petitioner’s 1999
Federal income tax return was selected for audit by computer and
not in retaliation for his complaints against his coworkers or
his job performance.
Petitioner also alleges that respondent violated section
7213, an issue which he did not raise in his District Court case.
However, pursuant to the judicial doctrine of collateral
estoppel, “the parties to the suit and their privies are
thereafter bound ‘not only as to every matter which was offered
and received to sustain or defeat the claim or demand, but as to
any other admissible matter which might have been offered for
that purpose.’” Commissioner v. Sunnen, supra at 597 (quoting
Cromwell v. County of Sac, 94 U.S. 351, 352 (1877)).
Accordingly, the Court will grant respondent’s motion for summary
judgment.
The Court has considered all of petitioner’s contentions,
arguments, requests, and statements. To the extent not discussed
herein, we conclude that they are meritless, moot, or irrelevant.
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