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TAYLOR v. COMMISSIONER

Docket No. 8493-96.

73 T.C.M. 2028 (1997)

T.C. Memo. 1997-82

Jeff R. Taylor v. Commissioner.

United States Tax Court.

Filed February 18, 1997.

Attorney(s) appearing for the Case

John C. Meaney, Portland, Ore., for the petitioner. Shirley M. Francis, for the respondent.

MEMORANDUM OPINION

PARR, Judge:

Respondent moves for partial summary judgment under Rule 121,1 arguing that petitioner's plea of guilty to criminal fraud under section 7201 collaterally estops him from rebutting her determination for the taxable year 1987 that he is liable for civil fraud under section 6653(b) for filing a false and fraudulent income tax return with the intent to evade income tax. Respondent further maintains...

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