Hooven & Allison Co. v. Lindley

In the case at bar, this court must first decide whether the doctrine of collateral estoppel bars the commissioner from imposing an ad valorem property tax upon imported raw goods stored by Hooven in its warehouse.

In Montana v. United States (1979), 440 U.S. 147, the United States Supreme Court clearly set forth the operational features of the interrelated doctrines of res judicata and collateral estoppel. The court therein declared:

“* * * Under res judicata, a final judgment on the merits bars further claims by parties or their privies based on the same cause of action. * * * Under…