United States Fourth Circuit

McHan v. Comm'r. of Int'l. Rev., 07-1834

Read McHan v. Comm'r. of Int'l. Rev., 07-1834
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In an appeal from a Tax Court deficiency judgment, judgment for the IRS is affirmed, where prior criminal proceedings against Plaintiff did not have a collateral estoppel effect because different parties bore the burden of proof in the Tax Court and criminal matters.

Appellate Information

Decided 02/27/2009
Published 02/27/2009

Judges

Before WILKINSON, DUNCAN, and AGEE, Circuit Judges.

Court

United States Fourth Circuit

Counsel

For Appellees:
ARGUED: Andrew Brady Banzhoff, Asheville, North Carolina, for Appellant. Curtis Clarence Pett, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Nathan J. Hochman, Assistant Attorney General, Kenneth L. Greene, Tax Division, United States Department of Justice, Washington, D.C., for Appellee.