STARLING v. COMMISSIONER

Docket No. 9689-88.

57 T.C.M. 1129 (1989)

T.C. Memo. 1989-392

Edward Starling v. Commissioner.

United States Tax Court.

Filed July 31, 1989.


Attorney(s) appearing for the Case

Edward Starling, pro se. Victoria Gunn, for the respondent.


Memorandum Opinion

GERBER, Judge:

Petitioner, in a motion filed February 3, 1989, moved for summary judgment on grounds which had some resemblance to the legal concepts of double jeopardy, res judicata or collateral estoppel. Petitioner argued that he was entitled to summary judgment because of the preclusive effect of a prior criminal proceeding on the instant civil proceeding. Separately, on April 14,...

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