Walter Anderson v. Commissioner of Internal Reven

OPINION

ROTH, Circuit Judge:

This appeal arises out of a civil tax fraud proceeding in United States Tax Court. The taxpayer challenges the Tax Court’s determination that, under the doctrine of collateral estoppel, his previous guilty plea for criminal tax evasion conclusively established the taxability to him of specific income that his criminal indictment charged him with failing to report. He additionally argues on the basis of a number of preclusion doctrines that the Internal Revenue’s (IRS) concession of all tax deficiency and penalty issues for certain years should have prevented it from…