George MacIel v. Commissioner of Internal Revenue

OPINION

WILLIAM A. FLETCHER, Circuit Judge.

George Maciel appeals from a decision of the United States Tax Court, which upheld an Internal Revenue Service (“IRS”) Notice of Deficiency for the 1990, 1991, and 1992 tax years. In a separate proceeding, Maciel pled guilty to criminal tax charges. As part of its sentencing decision in that case, the federal district court found that Maciel had not fraudulently intended to evade the payment of taxes. Maciel contends that, under the doctrine of collateral estoppel, the sentencing court’s finding should have precluded relitigation of the fraud issue…