Kevin J. Morse v. Commissioner of Internal Revenue Service

BYE, Circuit Judge.

Kevin J. Morse appeals the tax court’s 1 decision ordering him to pay tax deficiencies and civil fraud penalties under 26 U.S.C. § 6663 for unreported income during the years 1991 through 1994. Morse challenges the tax court’s finding of fraud, and he argues because a district court previously ordered him to pay $61,700 in restitution for the same unpaid taxes after a criminal conviction for filing false income tax returns under 26 U.S.C. § 7206(1), the doctrines of res judicata, collateral estop-pel, and double jeopardy prevent the Commissioner of Internal Revenue from…