DISTRICT OF COLUMBIA OFFICE OF TAX & REVENUE v. EXXONMOBILE OIL CORPORATION

KING, Senior Judge:

^Petitioner District of Columbia Office of Tax and Revenue (“OTR”) petitions for review of three orders issued by the Office of Administrative Hearings (“OAH”) that grant summary judgment to respondents Exxon Mobil Oil Corp., Shell Oil Co., and Hess Corp. (collectively, the “oil companies”) and reverse OTR’s Notices of Proposed Assessment of Tax Deficiency against them. OTR contends that OAH’s grant of summary judgment to the oil companies is premised on the erroneous application of offensive 1 non-mutual collateral estoppel against OTR. In United States v. Mendoza, 464…