When criminal tax proceedings are followed by civil tax proceedings, the legal doctrine of collateral estoppel may apply.
This doctrine provides that an issue necessarily decided in a previous proceeding will determine the issue in a subsequent proceeding but only as to matters in the second proceeding that were actually presented and determined in the first proceeding. A conviction for criminal tax evasion collaterally estops the taxpayer from contesting the existence of tax fraud for purposes of the civil tax fraud penalty because a finding of criminal tax fraud (beyond a reasonable doubt) establishes proof of civil tax fraud (by clear and convincing evidence).
Agenda
Faculty
Gary S. Wolfe
The Wolfe Law Group
Our author, Gary S. Wolfe, has more than 34 years of experience, specializing in IRS Tax Audits and International Tax Planning/Tax Compliance, and International Asset Protection.
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