George MacIel v. Commissioner of Internal Revenue

How courts have described this case

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

• explaining the factors used to determine whether a party had a full and fair opportunity to litigate an issue
• explaining the factors used to determine whether a party had a full and fair opportunity to litigate an issue
• analyzing the government’s incentives to litigate in the first proceeding then denying issue preclusion
• “If a party had good reason not to contest an issue vigorously during the first action 9 and did not, in fact, vigorously contest the issue, that party generally should be entitled to 10 relitigate the issue during the second action.”
• listing “badges of fraud” to support tax penalty

Source: CourtListener parenthetical corpus (CC0).