Hagan v. Appellate Department of the Superior Court of California

How later courts describe this case

• on remand, plaintiff could not raise claim of breach of warranty because issue of defectiveness of aircraft was conclusively litigated
• Sec. 7206 (1) is similar in nature to a peijury prosecution which makes the gravamen of the offense false swearing as to a material matter.
• “The law appears well established that a nunc pro tunc decree in proceedings to which the Internal Revenue Service is not a party is not binding on that Service for tax purposes.”