David Yuska v. Iowa Department of Revenue, 16-6022

Debtor David Eugene Yuska filed Chapter 13 in Sept. 2014, later converted to Chapter 7; he sued the Iowa Department of Revenue seeking to set aside tax assessments for 2004–2013.
The Department defended by asserting claim and issue preclusion based on a prior administrative proceeding, and moved for summary judgment on the amount and validity of assessed taxes.
Yuska advanced multiple defenses including that Iowa’s income tax statute is unconstitutional/vague, that Iowa improperly relied on IRS information, that he had renounced U.S. citizenship/Iowa residency, and that assessments (including 75% fraud penalties for 2011–2013) were improper.
The bankruptcy court denied Yuska’s late motion to submit new evidence, concluded there were no genuine material factual disputes, and applied claim and issue preclusion to bar adjudication of matters already decided by an administrative law judge (notably the 2007 assessment and challenges to the statute/procedure).
The court upheld the fraud penalties as supported by clear and convincing evidence, rejected citizenship/residency and federal-law-based nonliability arguments, and entered summary judgment for the Department.
Yuska appealed, raising denial of his new-evidence motion and constitutional/vagueness attacks on the Iowa income tax statute; the Bankruptcy Appellate Panel affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of motion to file new evidence	Yuska argued the court wrongly refused to consider newly discovered evidence/arguments	Dept. argued the motion was untimely, procedural rules not met, and parties had ample time to supplement	Denial affirmed — motion was not truly newly discovered evidence and denial was not an abuse of discretion
Preclusion of 2007 tax claim (res judicata/claim preclusion)	Yuska contended the bankruptcy court should decide his 2007 tax liability	Dept. argued the administrative law judge previously decided the 2007 issue and that decision is preclusive under Iowa law	Affirmed — prior ALJ decision is a final judgment with res judicata effect; claim barred
Challenge to constitutionality/procedure (issue preclusion)	Yuska argued Iowa income tax statute and assessment procedures are unconstitutional/vague	Dept. argued these issues were litigated and rejected in the administrative proceeding; thus collaterally estopped	Affirmed — issue preclusion applies because the identical issues were actually litigated and were essential to the prior judgment
Void-for-vagueness attack raised on appeal	Yuska argued the statute is unconstitutionally vague (first raised on appeal)	Dept. relied on prior Iowa Supreme Court holdings upholding the statute and procedural bars to re-litigating state-court rulings	Rejected — argument not considered as a new factual contention and fails on merits given controlling Iowa precedent

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting framework)
Schaaf v. Residential Funding Corp., 517 F.3d 544 (8th Cir. 2008) (standard of review for summary judgment cited)
Greyhound Lines, Inc. v. Wade, 485 F.3d 1032 (8th Cir. 2007) (standard for newly discovered evidence under Rule 60(b)(2))
George v. D.W. Zinser Co., 762 N.W.2d 865 (Iowa 2009) (administrative determinations have same preclusive effect as court judgments)
Hale v. Bd. of Assessment & Revenue, 271 N.W. 168 (Iowa 1937) (Iowa Supreme Court upheld constitutionality of income tax statute)