ANDERSON v. C.I.R.

No. 11-1704.

698 F.3d 160 (2012)

Walter C. ANDERSON, Appellant v. COMMISSIONER of INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Opinion filed: September 7, 2012.


Attorney(s) appearing for the Case

Steven J. Jozwiak, Esquire , (Argued) Cherry Hill, NJ, for Appellant.

Gilbert S. Rothenberg, Esquire , Acting Deputy Assistant Attorney General, Bethany B. Hauser, Esquire , (Argued) Robert W. Metzler, Esquire, Francesca U. Tamami, Esquire , United States Department of Justice, Tax Div., Washington, DC, for Appellee.

Before: SLOVITER and ROTH, Circuit Judges and POLLAK, District Judge.


OPINION

ROTH, Circuit Judge:

This appeal arises out of a civil tax fraud proceeding in United States Tax Court. The taxpayer challenges the Tax Court's determination that, under the doctrine of collateral estoppel, his previous guilty plea for criminal tax evasion conclusively established the taxability to him of specific income that his criminal indictment charged him with failing to report. He additionally argues on the basis of a number of preclusion...

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