Leo Manzoli and Mary Ann Manzoli v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• party to civil action collaterally estopped from relitigating material issue resolved against him in prior crimi- nal action
• guilty plea to tax evasion “is as much a conviction as a jury trial” and estops the convict from denying fraud in subsequent civil action, quoting from Gray v. Commissioner, 708 F.2d 243, 246 [6th Cir. 1983], cert, denied, 466 U.S. 927 [1984]

Source: CourtListener parenthetical corpus (CC0).