7--CHANG 739-748
PageMaker 6.5
NOTES 739 Tax Lawyer, Vol. 53, No. 3 NOTE COLLATERAL ESTOPPEL DEFENSE DISALLOWED WHEN NOT INITIALLY RAISED DURING ADMINISTRATIVE PROCEEDING: TRUE V. UNITED STATES In True v. United States,1 the U.S. Court of Appeals for the Tenth Circuit held that collateral estoppel claims omitted from an administrative refund filing were deemed waived for purposes of judicial review. The court then applied the step transaction doctrine to taxpayers’ oil and gas transactions and concluded that the district court...