MEMORANDUM OPINION
LARO, Judge:
Respondent moves for partial summary judgment, arguing that petitioner's plea of guilty to criminal fraud under section 7201 collaterally estops him from rebutting her determination that he is liable for civil fraud under section 6653(b) for the same years. Respondent supports her motion with two exhibits, namely: (1) A grand jury indictment (Indictment) of petitioner and Andrew Winslow Willis, and (2) petitioner's plea agreement...
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