WESLEY E. BROWN, Senior District Judge.
This is an appeal from a decision of the United States Tax Court which sustained the Commissioner’s determination of certain deficiencies in the federal tax returns of appellant, Paul F. Gray, Jr., for the years 1968, 1969, and 1970, which imposed certain fraud penalties pursuant to 26 U.S.C. § 6653(b). In particular, the Tax Court found that Gray was collaterally estopped from denying that his returns for the years in question were fraudulent, in view of his previous pleas of guilty to charges of income tax evasion for those years.
The only issue presented for review in this appeal is whether or not the Tax Court was correct in holding that Gray was collaterally estopped from denying liability for civil penalties as a result of his guilty pleas under 26 U.S.C. § 7201.
Appellant was indicted March, 1975 in the Eastern District of Tennessee on three counts of knowingly and willfully attempting to evade and defeat income taxes for the years 1968, 1969 and 1970, by submitting false returns, in violation of 26 U.S.C. § 7201.1 Gray pled guilty to each count of the indictment and received a sentence of 18 months on Count I, two years’ probation on Counts II and III, and a fine of $2,000 on each of the three counts. The sentence on Count I was suspended except for 100 days to be served in a “jail type” institution. At the time the pleas were entered Gray was aware of the fact that no disposition was being made of his civil tax liabilities.
In April, 1976, after the criminal matter was disposed of, the Commissioner issued the required statutory notices of deficiency for the taxable years 1968-1970, including additional civil penalties provided by 26 U.S.C. § 6653(b),2 in the following amounts: **
[245]*245Year Deficiency Additions
1968 $22,466.07 $11,223.03
1969 40,767.94 20,383.97
1970 39,134.47 19,567.233
Gray petitioned the Tax Court for a rede-termination of the asserted deficiencies, and additions to the tax. The United States filed a motion for partial summary judgment, alleging that Gray was collaterally estopped, by his plea of guilty in the criminal tax prosecution, from denying liability for civil penalties under Section 6652(b). In opposing the motion, Gray contended that his pleas were not conclusive in regard to civil penalties, and he sought partial summary judgment to the effect that any deficiency should be limited to the amounts alleged in the criminal indictment, with civil fraud penalties to be limited to 50% of those figures.
On November 27, 1979, the Tax Court granted the government’s motion for partial summary judgment, and denied Gray’s motion, ruling that Gray was “collaterally estopped from denying that parts of the underpayments of income tax for the taxable years .. . are due to fraud.”
Gray next filed in the criminal case in Tennessee a petition for a Writ of Error Coram Nobis for the purpose of vacating and setting aside his convictions, and to permit him to withdraw his pleas of guilty in that proceeding. The petition was denied and this decision was affirmed by this Circuit, without published opinion, Gray v. United States of America, 663 F.2d 1071 (6th Cir.1981). In that appeal, a panel of this court determined that the collateral estoppel effect of a guilty plea in a later civil tax case is a collateral consequence of the guilty plea, and that it was therefore unnecessary for the district court to have specifically advised Gray of the collateral consequences of his plea. It was further held that there was no evidence that the United States Attorney had misled Gray in any respect regarding the separate issue of his civil tax liabilities.4
After further hearing in the Tax Court, the parties agreed to the Commissioner’s computations, and under stipulated facts, it was found that Gray had additional taxable income of $53,543.83, $69,736.76, and $106,-141.66, respectively for the years 1968,1969, and 1970. From these figures, the Tax Court determined that tax deficiencies for those years were in the sums of $19,534.11, $27,594.80, and $38,054.96. Additions to these taxes under the provisions of § 6653(b) were found to be in the amounts of $9,767.06, $13,979.40, and $19,027.48.
In this appeal, Gray contends that it was error to apply the doctrine of collateral estoppel because estoppel operates only upon matters and questions actually litigated. Appellant claims that his guilty pleas in the criminal case, were like a consent decree in a civil case, and not an adjudication on the merits of the fraud issue.
While Gray concedes that there are federal cases which would permit the application of collateral estoppel in this instance, he argues that such cases are distinguishable, and not applicable to his situation. He further contends that such cases are not binding upon this court, that they are in conflict with “the weight of state authorities on the issue,” and that an application of collateral estoppel here would conflict with the holding of the Supreme Court in United States v. International Building Co., 345 U.S. 502, 73 S.Ct. 807, 97 L.Ed. 1182 (1953).
In International Building, deficiencies were assessed against the corporate taxpayer for the years 1933, 1938, and 1939, be[246]*246cause of a determination that taxpayer had used an improper basis of depreciation for certain property. By a joint stipulation, the deficiencies were abated and the Tax Court entered decisions that there were no deficiencies for those years. In 1948, the Commissioner assessed deficiencies in taxes for the years 1943, 1944, and 1945, again challenging the basis for depreciation used by taxpayer. After paying the deficiencies and suing for refund, the taxpayer claimed that the prior decisions regarding taxable years 1933, 1938 and 1939 were res judicata as to the question of the proper basis for depreciation. In determining that the prior decision was not binding, the court found that it was not clear that the merits of the depreciation dispute had been determined in the first case.
The International Building case is clearly distinguishable from Gray’s situation. The record establishes that the District Court fully examined appellant with respect to his understanding of the charges contained in the indictment, and Gray affirmatively stated that he had indeed filed false tax returns, and that he had done so, with the intent to evade the payment of taxes.5 The record is clear that Gray voluntarily chose to plead guilty to the charges, and a forthright judicial determination was made that he was guilty as charged in each instance.
A guilty plea is as much a conviction as a conviction following jury trial. The elements of criminal tax evasion and civil tax fraud are identical. See Hicks Co., Inc.
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WESLEY E. BROWN, Senior District Judge.
This is an appeal from a decision of the United States Tax Court which sustained the Commissioner’s determination of certain deficiencies in the federal tax returns of appellant, Paul F. Gray, Jr., for the years 1968, 1969, and 1970, which imposed certain fraud penalties pursuant to 26 U.S.C. § 6653(b). In particular, the Tax Court found that Gray was collaterally estopped from denying that his returns for the years in question were fraudulent, in view of his previous pleas of guilty to charges of income tax evasion for those years.
The only issue presented for review in this appeal is whether or not the Tax Court was correct in holding that Gray was collaterally estopped from denying liability for civil penalties as a result of his guilty pleas under 26 U.S.C. § 7201.
Appellant was indicted March, 1975 in the Eastern District of Tennessee on three counts of knowingly and willfully attempting to evade and defeat income taxes for the years 1968, 1969 and 1970, by submitting false returns, in violation of 26 U.S.C. § 7201.1 Gray pled guilty to each count of the indictment and received a sentence of 18 months on Count I, two years’ probation on Counts II and III, and a fine of $2,000 on each of the three counts. The sentence on Count I was suspended except for 100 days to be served in a “jail type” institution. At the time the pleas were entered Gray was aware of the fact that no disposition was being made of his civil tax liabilities.
In April, 1976, after the criminal matter was disposed of, the Commissioner issued the required statutory notices of deficiency for the taxable years 1968-1970, including additional civil penalties provided by 26 U.S.C. § 6653(b),2 in the following amounts: **
[245]*245Year Deficiency Additions
1968 $22,466.07 $11,223.03
1969 40,767.94 20,383.97
1970 39,134.47 19,567.233
Gray petitioned the Tax Court for a rede-termination of the asserted deficiencies, and additions to the tax. The United States filed a motion for partial summary judgment, alleging that Gray was collaterally estopped, by his plea of guilty in the criminal tax prosecution, from denying liability for civil penalties under Section 6652(b). In opposing the motion, Gray contended that his pleas were not conclusive in regard to civil penalties, and he sought partial summary judgment to the effect that any deficiency should be limited to the amounts alleged in the criminal indictment, with civil fraud penalties to be limited to 50% of those figures.
On November 27, 1979, the Tax Court granted the government’s motion for partial summary judgment, and denied Gray’s motion, ruling that Gray was “collaterally estopped from denying that parts of the underpayments of income tax for the taxable years .. . are due to fraud.”
Gray next filed in the criminal case in Tennessee a petition for a Writ of Error Coram Nobis for the purpose of vacating and setting aside his convictions, and to permit him to withdraw his pleas of guilty in that proceeding. The petition was denied and this decision was affirmed by this Circuit, without published opinion, Gray v. United States of America, 663 F.2d 1071 (6th Cir.1981). In that appeal, a panel of this court determined that the collateral estoppel effect of a guilty plea in a later civil tax case is a collateral consequence of the guilty plea, and that it was therefore unnecessary for the district court to have specifically advised Gray of the collateral consequences of his plea. It was further held that there was no evidence that the United States Attorney had misled Gray in any respect regarding the separate issue of his civil tax liabilities.4
After further hearing in the Tax Court, the parties agreed to the Commissioner’s computations, and under stipulated facts, it was found that Gray had additional taxable income of $53,543.83, $69,736.76, and $106,-141.66, respectively for the years 1968,1969, and 1970. From these figures, the Tax Court determined that tax deficiencies for those years were in the sums of $19,534.11, $27,594.80, and $38,054.96. Additions to these taxes under the provisions of § 6653(b) were found to be in the amounts of $9,767.06, $13,979.40, and $19,027.48.
In this appeal, Gray contends that it was error to apply the doctrine of collateral estoppel because estoppel operates only upon matters and questions actually litigated. Appellant claims that his guilty pleas in the criminal case, were like a consent decree in a civil case, and not an adjudication on the merits of the fraud issue.
While Gray concedes that there are federal cases which would permit the application of collateral estoppel in this instance, he argues that such cases are distinguishable, and not applicable to his situation. He further contends that such cases are not binding upon this court, that they are in conflict with “the weight of state authorities on the issue,” and that an application of collateral estoppel here would conflict with the holding of the Supreme Court in United States v. International Building Co., 345 U.S. 502, 73 S.Ct. 807, 97 L.Ed. 1182 (1953).
In International Building, deficiencies were assessed against the corporate taxpayer for the years 1933, 1938, and 1939, be[246]*246cause of a determination that taxpayer had used an improper basis of depreciation for certain property. By a joint stipulation, the deficiencies were abated and the Tax Court entered decisions that there were no deficiencies for those years. In 1948, the Commissioner assessed deficiencies in taxes for the years 1943, 1944, and 1945, again challenging the basis for depreciation used by taxpayer. After paying the deficiencies and suing for refund, the taxpayer claimed that the prior decisions regarding taxable years 1933, 1938 and 1939 were res judicata as to the question of the proper basis for depreciation. In determining that the prior decision was not binding, the court found that it was not clear that the merits of the depreciation dispute had been determined in the first case.
The International Building case is clearly distinguishable from Gray’s situation. The record establishes that the District Court fully examined appellant with respect to his understanding of the charges contained in the indictment, and Gray affirmatively stated that he had indeed filed false tax returns, and that he had done so, with the intent to evade the payment of taxes.5 The record is clear that Gray voluntarily chose to plead guilty to the charges, and a forthright judicial determination was made that he was guilty as charged in each instance.
A guilty plea is as much a conviction as a conviction following jury trial. The elements of criminal tax evasion and civil tax fraud are identical. See Hicks Co., Inc. v. C.I.R., 470 F.2d 87, 90 (1 Cir.1972); Moore v. United States, 360 F.2d 353, 356 (4 Cir.1965, as modified), cert. den. 385 U.S. 1001, 87 S.Ct. 704, 17 L.Ed.2d 541 (1967).
Numerous federal courts have held that a conviction for federal income tax evasion, either upon a plea of guilty, or upon a jury verdict of guilt, conclusively establishes fraud in a subsequent civil tax fraud proceeding through application of the doctrine of collateral estoppel. See Fontneau v. United States, 654 F.2d 8, 10 (1 Cir.1981) (guilty plea); Plunkett v. C.I.R., 465 F.2d 299, 305-307 (7 Cir.1972) (guilty plea); Neaderland v. C.I.R., 424 F.2d 639, 642 (2d Cir.1970) cert. den. 400 U.S. 827, 91 S.Ct. 53, 27 L.Ed.2d 56 (1970); Moore v. United States, supra, 360 F.2d 353 at 355-356 (conviction following trial); Amos v. C.I.R., 360 F.2d 358 (4 Cir.1965) affirming 43 T.C. 50; Armstrong v. United States, 354 F.2d 274, 291 (Ct.Cl.1965) (conviction following trial); Tomlinson v. Lefkowitz, 334 F.2d 262, 264-265 (5 Cir.1964) cert. den. 379 U.S. 962, 85 S.Ct. 650, 13 L.Ed.2d 556 (1965) (conviction following trial.) See also, Arctic Ice Cream Co. v. Commissioner, 43 T.C. 68, 75 (1964) and the recent decisions in Acker v. United States, (N.D.Ohio 1981) 519 F.Supp. 178, 182, and Considine v. United States, 683 F.2d 1285 (9 Cir.1982).
In the face of the foregoing authorities, appellant’s citation of state cases is not persuasive. Indeed, he recognizes that “most of the federal cases take the opposite position” to that which he urges in this appeal.6 We conclude that appellant’s contention that he has been denied his day in court with respect to the issue of fraud is without merit.
[247]*247The judgment of the Tax Court is Affirmed.