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                        as a courtesy to the reader. They are not part of the opinion of the court.

142342P.pdf   07/29/2015  Gary Kaplan  v.  CIR
   U.S. Court of Appeals Case No:  14-2342
   The United States Tax Court   
   [PUBLISHED] [Bye, Author, with Beam and Smith, Circuit Judges] 
   U.S. Tax Court. Kaplan's failure to file a tax return for the 2004 and 
   2005 tax years allowed the Commissioner to assess taxes or initiate a 
   civil tax proceeding at any time, and this civil action was not barred by 
   the three-year statute of limitations; nor was this civil tax proceeding 
   barred by defendant's guilty plea agreement in his criminal proceeding for 
   running an illegal online gambling business or the doctrine of judicial 
   estoppel.