- 5 - (4) The parties must actually have litigated the issues and the resolution of these issues must have been essential to the prior decision. (5) The controlling facts and applicable legal rules must remain unchanged from those in the prior litigation. [Peck v. Commissioner, 90 T.C. 162, 166- 167 (1988); citations omitted.] Collateral estoppel is "designed to prevent repetitious lawsuits over matters which have once been decided and which have remained substantially static, factually and legally." Commissioner v. Sunnen, 333 U.S. 591, 599 (1948). By denying relitigation, judicial energy is conserved, and parties may reasonably rely on the fact that they will not have to relitigate issues that have already been determined by a court. See Fink v. Commissioner, 60 T.C. 867 (1973), affd. 512 F.2d 674 (9th Cir. 1975). In Beck I, this Court rendered a final judgment. The parties in Beck I and this case are identical. Since the decision in Beck I, the controlling facts and applicable legal rules have not changed. The sole question is whether the issue decided in Beck I is identical in all respects to the issue in this case. If the issues are identical, then collateral estoppel applies because the issue was fully litigated and essential to the decision in Beck I. In Beck I, petitioners claimed that their rental income was exempt from taxation by article 10 of the 1866 Treaty, 14 Stat. 801. In that case, we held:Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011