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042040P.pdf   08/22/2005  Kevin J. Morse  v.  CIR
   U.S. Court of Appeals Case No:  04-2040
   Agency   
   [PUBLISHED] [Bye, Author, with Heaney and Melloy, Circuit Judges] 
   Civil case - Federal Tax. Morse's tax fraud conviction, together with 
   consistent underreporting of income, lack of a satisfactory explanation, 
   and failure to provide his tax preparer with complete information, 
   provided a substantial body of evidence to support the tax court's finding 
   of tax fraud; neither res judicata nor collateral estoppel precluded the 
   imposition of civil liability for tax deficiency or fraud penalties; 
   imposition of fraud penalties did not violate the Double Jeopardy clause 
   as the penalties are remedial in nature, rather than criminal.