MORSE v. C.I.R.

No. 04-2040.

419 F.3d 829 (2005)

Kevin J. MORSE, Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: August 22, 2005.


Attorney(s) appearing for the Case

Lawrence H. Crosby, St. Paul, MN, for appellant.

Carol Barthel and Frank P. Cihlar, Justice Dept. of Washington, DC, for appellee.

Before BYE, HEANEY, and MELLOY, Circuit Judges.


BYE, Circuit Judge.

Kevin J. Morse appeals the tax court's1 decision ordering him to pay tax deficiencies and civil fraud penalties under 26 U.S.C. § 6663 for unreported income during the years 1991 through 1994. Morse challenges the tax court's finding of fraud, and he argues because a district court previously ordered him to pay $61,700 in restitution for the same unpaid taxes after a criminal conviction for filing false income...

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