noting that a guilty plea has collateral estoppel effect
How later courts described this case
- noting that a guilty plea has collateral estoppel effect
- improper inducement of defendant's waiver of right to appeal criminal judgment tainted the judgment's finality for collateral estoppel purposes
- "This conviction [for criminal tax fraud] necessarily carries with it the ultimate factual determination that the resulting deficiency * * * was [attributable to civil tax fraud]"
- " a plea of guilty * * * is a conclusive judicial admission of all of the essential elements of the offense which the indictment charges"
Written by the judges who cited it.
The opinion
PiERCE, J., dissenting: I respectfully dissent from the Court’s decision in this case, for the reasons which I have rather extensively set forth in my dissenting opinion in the concurrently considered case of John W. Amos, 43 T.C. 50 .