PER CURIAM.
Albert H. Fontneau appeals the district court's grant of summary judgment in favor of the Government on the issue of Fontneau's liability for civil tax fraud penalties for the year 1968. Fontneau contends that the doctrine of collateral estoppel does not bar him from relitigating the issue of fraud as determined in his criminal conviction for tax evasion for the year 1968. We disagree, and affirm the district court.
In March 1973, Fontneau was...
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