John W. AMOS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, 360 F.2d 358

Summary

The taxpayer sought a refund of additional taxes and penalties assessed and paid, but the tax court entered a judgment for the commissioner. On appeal, the court upheld the tax court's judgment, holding that the tax court properly determined that the taxpayer's prior criminal conviction for tax evasion worked a collateral estoppel on the issue of fraud in the case. The court also held that the tax court's invocation of the doctrine of collateral estoppel raised no issue of constitutional dimensions in the case because the tax court exercised judicial functions in the decision of tax cases and was bound to apply fundamental judicial doctrines such as collateral estoppel.