Hudson v. Commissioner
United States Tax Court
Held: Under the doctrine of collateral estoppel, where a trial court's judgment in an earlier proceeding is affirmed by an appellate court on grounds different from those relied upon by the trial court, the findings of fact of the trial court are not binding in a subsequent proceeding in this Court between the same parties.
1Opinion of the Court
OPINION
Swift, Judge:
After trial on March 5, 1993, the parties were asked by the Court to submit briefs on one of the primary legal arguments made by petitioner herein; namely, whether respondent is barred by collateral estoppel from contesting the value of certain master educational audio tapes (master audio tapes) as found by a Federal District Court in an injunction proceeding under sections 6700 and 7408.
Respondent determined deficiencies in and additions to petitioner’s individual Federal income taxes as follows:
Additions to tax
Year Deficiency Sec. 6621(c) Sec. 6653(b) Sec. 6653(b)(1)…
2Cases cited18 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Joseph Gelb v. Royal Globe Insurance CompanyCourt of Appeals for the Second Circuit · 1986
- Robert J. Meza v. General Battery Corporation and Provident Life and Accident Insurance CompanyCourt of Appeals for the Fifth Circuit · 1990
13 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Monahan v. CommissionerUnited States Tax Court · 1997
- Estate of Posner v. Comm'rUnited States Tax Court · 2004
- Gould v. Comm'rUnited States Tax Court · 2012
- Hudson v. CommissionerUnited States Tax Court · 1994
- Barrett-Crofoot Invs. v. CommissionerUnited States Tax Court · 1994
7 more not listed; retrieve them via the Exa API.