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Supreme Court· 4/19/1948

Commissioner v. Sunnen

Citations

  • 333 U.S. 591
  • 68 S. Ct. 715
  • 92 L. Ed. 2d 898
  • 1948 U.S. LEXIS 2852

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • holding that a judicial declaration intervening between the two proceedings may so change the legal atmosphere as to render the rule of collateral estoppel inapplicable
  • holding that a judicial declaration intervening between the two proceedings may so change the legal atmosphere as to render the rule of collateral estoppel inapplicable
  • ruling that parties to a cause of action are bound by final judgments on the merits
  • holding that a judgment relating to liability for a particular tax year is res judicata as to the same claim and the same tax year
  • holding that “where the situation is vitally altered between the time of the first judgment and the second, the prior determination is not conclusive.”
  • holding that review of CDP determinations extends only to those issues raised before the IRS Office of Appeals

Source: CourtListener parenthetical corpus (CC0).

Judges: Murphy, Rutledge, Frankfurter, Tax, Dobson, American

Read full opinion on CourtListener

Cited by

1,494 cases in this archive cite this case; the 20 most cited are listed.

Cites

32 cases in this archive are cited by this case; the 20 most cited are listed.

Other cases named Commissioner v. Sunnen

1 other CourtListener record shares this case name.

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.