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M.J. WOOD ASSOCIATES, INC. v. COMMISSIONER

Docket Nos. 10978-94, 11982-94.

76 T.C.M. 700 (1998)

T.C. Memo. 1998-375

M.J. Wood Associates, Inc., v. Commissioner. Lonnie C. Christensen v. Commissioner.

United States Tax Court.

Filed October 15, 1998.

Attorney(s) appearing for the Case

William A. Cohan, for the petitioners. Paul K. Voelker, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

We consider in these consolidated cases petitioners' motion for summary judgment. Petitioners contend that the instant action is barred by the doctrines of res judicata and collateral estoppel because restitution orders, which were part of the judgment in a criminal proceeding, constitute an adjudication of the amounts of tax, interest, and penalties owed by petitioners. Respondent contends that petitioners are not entitled...

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