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WAPNICK v. C.I.R.

No. 02-4172.

365 F.3d 131 (2004)

Harold WAPNICK, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided: April 16, 2004.

Attorney(s) appearing for the Case

Harold Wapnick, Brooklyn, NY, pro se, for Appellant.

On Submission (Eileen J. O'Connor, Assistant Attorney General, U.S. Dept. of Justice, Thomas J. Clark and Joel McElvain, Attorneys, U.S. Dept. of Justice, on the brief), for Appellee.

Before: McLAUGHLIN and JACOBS, Circuit Judges, and COVELLO, District Judge.

PER CURIAM.

Harold Wapnick, pro se, appeals from a judgment of the United States Tax Court (Colvin, J.), entered on April 9, 2002. Wapnick primarily challenges the Tax Court's ruling that he is collaterally estopped by his conviction in a prior criminal proceeding from contesting an additional tax penalty due to fraud. For the reasons that follow, we conclude that this Court lacks jurisdiction to consider the appeal.

I

Wapnick was convicted...

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