J. BLAINE ANDERSON, Circuit Judge:
Considine appeals from summary judgment entered in favor of the Government in his tax refund suit. He contends that the district court erred in holding that his prior conviction for filing a false return collaterally estopped him from contesting liability for a civil fraud penalty. We affirm, although for reasons different from those relied on by the district court.
FACTS
Charles and Thalia Considine filed a joint...
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