Gerald Hickman v. Commissioner of Internal Revenue

OPINION

ALAN E. NORRIS, Circuit Judge.

Appellant Gerald Hickman appeals the United States Tax Court’s decision that the Commissioner of Internal Revenue was not collaterally estopped from collecting a deficiency in appellant’s income taxes despite the fact that he previously had paid a tax deficiency (albeit incorrectly calculated) as part of his sentence resulting from his conviction for failure to file tax returns. We affirm the decision of the tax court.

I

Although appellant worked on an independent contractor basis from 1984 to 1988, he failed to file federal income tax returns for those…