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prior judgment is a bar in subsequent litigation. See Jones v.
United States, 466 F.2d 131, 136 (10th Cir. 1972); Cory v.
Commissioner, 159 F.2d 391, 392 (3d Cir. 1947), affg. a
Memorandum Opinion of this Court dated Mar. 10, 1945; Dean v.
Commissioner, 56 T.C. 895, 899-900 (1971); Milberg v.
Commissioner, 54 T.C. 1562 (1970); Fairmont Aluminum Co. v.
Commissioner, 22 T.C. 1377 (1954), affd. 222 F.2d 622 (4th Cir.
1955). Petitioner’s criteria would be impractical to apply in
the context of a doctrine intended to minimize multiplicity of
proceedings. See Jones v. United States, supra at 136; Dean v.
Commissioner, supra at 902. The related but broader doctrine of
collateral estoppel has been applied to decisions where the
taxpayer has appeared pro se in the prior proceeding. See
Calcutt v. Commissioner, supra at 25.
Under the narrow circumstances of this case, however, we
conclude that the general rule of res judicata should not apply.
Petitioner’s meeting with the Appeals officer handling her 1994
deficiency case occurred about the time that section 6015 was
being finalized by Congress and at least 10 days before its
effective date. Although the decision was entered pursuant to
the negotiated settlement months later, it appears that both the
Appeals officer and petitioner were ignorant as to the effect of
the new law. Res judicata was not discussed in the notice of
determination denying relief to petitioner or in the memorandum
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