Fischer v. United States

The Supreme Court of the United States, which has a broad supervisory power over the judgments of the lower federal courts,1 has squarely held that those courts, including the Tax Court 2 and the Court of Customs Appeals,3 shall embrace in their procedure the broad social principle of res judicata, which seeks to bring litigation to an end and promote certainty in legal relations.

Failure to enforce the doctrine by the two courts last named was described by the Supreme Court as “a fertile basis for litigious confusion.”2 However, there is no procedure available in those courts, such as a…