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ZUKOWSKI v. COMMISSIONER

Docket No. 2309-85.

59 T.C.M. 33 (1990)

T.C. Memo. 1990-113

Chester Zukowski, Jr. v. Commissioner.

United States Tax Court.

Filed March 7, 1990.

Attorney(s) appearing for the Case

Chester Zukowski, Fort Lauderdale, Fla., pro se. Julius Gonzalez, for the respondent.

Memorandum Opinion

RUWE, Judge:

This case is before the Court on respondent's motion for partial summary judgment, filed January 19, 1990, pursuant to Rule 121.1

Respondent's motion claims that he is entitled to summary judgment with respect to the fraud and statute of limitations issues on the grounds that petitioner is collaterally estopped from denying fraud for each of the years in issue, because of his previous conviction...

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