United States Third Circuit

The judgment of the Tax Court, in a civil tax fraud proceeding against a taxpayer is affirmed, where: 1) the taxpayer's conviction for tax evasion in 1998 and 1999 precludes him, by collateral estoppel, from contesting in subsequent civil fraud proceedings that the disputed income was taxable to him; and 2) the IRS's concession of all deficiency and penalty issues for the years at dispute has no preclusive effect on those issues for 1998 and 1999.

Appellate Information

• Decided 09/07/2012
• Published 09/07/2012

Judges

• Roth

Court

• United States Third Circuit

Counsel