Goichman v. Commissioner
United States Tax Court
Petitioner was convicted of violating I.R.C. section 7201 for the taxable years 1968 and 1969. In April 1983, respondent issued a notice of deficiency determining deficiencies and additions to tax for fraud under I.R.C. section 6653(b) for the years 1967, 1968 and 1969. Held, respondent met his burden of proving fraud by clear and convincing evidence for the taxable year 1967. Held further, petitioner's criminal conviction collaterally estops him from denying fraud for the…
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Petitioner was convicted of violating I.R.C. section 7201 for the taxable years 1968 and 1969. In April 1983, respondent issued a notice of deficiency determining deficiencies and additions to tax for fraud under I.R.C. section 6653(b) for the years 1967, 1968 and 1969. Held, respondent met his burden of proving fraud by clear and convincing evidence for the taxable year 1967. Held further, petitioner's criminal conviction collaterally estops him from denying fraud for the taxable years 1968 and 1969. Held further, the statute of limitations does not bar the assessment and collection of…
1Opinion of the Court
WILLIAM A. GOICHMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Goichman v. Commissioner
Docket No. 10042-83.
United States Tax Court
T.C. Memo 1987-489; 1987 Tax Ct. Memo LEXIS 485; 54 T.C.M. (CCH) 679; T.C.M. (RIA) 87489;
September 28, 1987.
Petitioner was convicted of violating I.R.C. section 7201 for the taxable years 1968 and 1969. In April 1983, respondent issued a notice of deficiency determining deficiencies and additions to tax for fraud under I.R.C. section 6653(b) for the years 1967, 1968 and 1969. Held, respondent met his burden of proving fraud by clear and convincing…
2Cases cited44 opinions
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- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Holland v. United StatesSupreme Court of the United States · 1955
- Commissioner v. SunnenSupreme Court of the United States · 1948
39 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
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