# Amos v. Commissioner

> United States Tax Court · October 21, 1964 · 43 T.C. 50

URL: https://www.frixlaw.com/law-library/cases/4480131

## Case

- **Full name:** John W. Amos v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** October 21, 1964
- **Citations:** 43 T.C. 50; 1964 U.S. Tax Ct. LEXIS 28
- **Precedential status:** Published
- **Opinion:** Concurrence by Mdlronet
- **Judges:** Dawson,Withey,Drennen
- **Cited by:** 192 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4480131

## Opinion text

MdlRONEt, J., concurring: I desire to say a word to emphasize my complete agreement with the majority opinion.
It may well be this opinion is an extension of the doctrine of collateral estoppel in the sense that it would not be within the concept of that doctrine as announced by the courts 50 years ago. But it is within the expanding scope of the doctrine as developed in more recent cases. An examination of the authorities shows the former limit of the doctrinal basis has received a practical extension. “Principles which perhaps stated the law correctly two decades ago no longer can be said to be valid. The key to preclusion now is not that certain parties have litigated, but rather that an issue has been adjudicated.” Vestal, “Preclusions/Res Judicata Variables: Parties,” 50 Iowa L. Rev. 21 ,76.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4480131. Public record. Not legal advice.