- 5 - period of limitation for collection of such deficiency had expired. Respondent's right to collect that deficiency continued, however, and she is now attempting to enforce that right using the remedy Congress provided when it codified the principles of transferee liability. Petitioners also contend that the doctrine of res judicata precludes respondent from collecting the estate tax deficiency from them. Specifically, petitioners argue that the doctrine of res judicata prevents respondent from relitigating the Court's decision in docket No. 15954-94 that no estate tax deficiency exists. Respondent disagrees. We hold for respondent. The doctrine of res judicata is applicable in the field of Federal taxation. United States v. International Bldg. Co., 345 U.S. 502, 506 (1953); Commissioner v. Sunnen, 333 U.S. 591, 598 (1948); Krueger v. Commissioner, 48 T.C. 824 (1967). It rests on principles of judicial economy and public policy favoring finality of litigation and certainty in legal relations. Commissioner v. Sunnen, supra. In Sunnen, the Supreme Court stated that the "judgment puts an end to the cause of action, which cannot again be brought into litigation between the parties upon any ground whatever, absent fraud or some other factor invalidating the judgment." Id. at 597. For the doctrine of res judicata to apply, three requirements must be satisfied: (1) The parties in the subsequent action must be the same as or in privity with thePage: Previous 1 2 3 4 5 6 7 8 Next
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