Gwinnett County Board of Tax Assessors v. General Electric Capital Computer Services

In these cases, we granted certiorari to determine whether the doctrine of collateral estoppel bars the relitigation of a tax issue where there has been no significant factual change, but where there has been a change or development in the law. In Division 1, the majority opinion correctly holds that collateral estoppel does not apply under those circumstances. In Division 2, however, the majority affirms the Court of Appeals, concluding that there was no such intervening change in the law regarding the eligibility of the inventory of General Electric Capital Computer Services (GECC) for the…