Legal Opinion
John W. Amos v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided December 7, 1965No. 9963PublishedCited by 203 opinions
1Opinion of the Court
SOBELOFF, Circuit Judge;
In Moore v. United States, 4 Cir., 360 F.2d 353, decided today, we held that a criminal conviction for tax evasion works a collateral estoppel on the issue of fraud in a subsequent civil suit over a fraud penalty covering the same years. For the reasons fully stated in that opinion, and which need not be repeated, we sustain the Tax Court’s reliance on collateral estoppel in the present proceeding.
This case is not significantly different. Moore was a suit in a district court by a taxpayer for the refund of additional taxes and penalties assessed and paid. We held…
2Cases cited6 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Glidden Co. v. ZdanokSupreme Court of the United States · 1962
- Fairmont Aluminum Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
- Jerome H. Moore and Mildred v. Moore v. United States of America, Jerome H. Moore and Mildred v. Moore v. United StatesCourt of Appeals for the Fourth Circuit · 1966
1 more not listed; retrieve them via the Exa API.
3Cited by203 opinions
- Stone v. CommissionerUnited States Tax Court · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Otsuki v. CommissionerUnited States Tax Court · 1969
- Niedringhaus v. CommissionerUnited States Tax Court · 1992
- Haldane M. Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1972
198 more not listed; retrieve them via the Exa API.