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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 the
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