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WAPNICK v. COMMISSIONER

Docket No. 269-94.

73 T.C.M. 2317 (1997)

T.C. Memo. 1997-133

Harold Wapnick v. Commissioner.

United States Tax Court.

Filed March 13, 1997.

Attorney(s) appearing for the Case

Harold Wapnick, pro se. Monica E. Koch, for the respondent.

MEMORANDUM OPINION

GALE, Judge:

This matter is presently before the Court on respondent's motion for partial summary judgment, in which respondent argues that the conviction of Harold Wapnick (petitioner) under section 72011 collaterally estops him from disputing that there is an underpayment of income tax, and that some part of the underpayment is due to fraud within the meaning of section 6653(b), for each of the 1985, 1986...

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