Wanta v. Wisconsin Dept of Revenue

1 Leo E. Wanta appeals a judgment upholding a decision of the Tax Appeals Commission that Wantas challenge to the Department of Revenues personal income tax assessments for 1988 and 1989 is barred by the doctrine of claim preclusion. Wanta argues that (1) claim preclusion does not apply to some of the issues he raises; (2) he is entitled to an accounting for revenues the Department received from the foreclosure sale of his property; (3) the Department should be bound by a letter from a revenue agent; and (4) Wanta should benefit from the Departments release of claims against Wantas ex-wife under the innocent spouse provisions of WIS. STAT.§ 71.10(6). Because we conclude that claim preclusion bars relitigation of Wantas tax assessment for 1988 and 1989 and other issues he attempts to raise are outside the scope of these proceedings, we affirm the judgment.