OPINION.
LEECH, Judge:
Respondent has determined that petitioner is liable as transferee of the Northwestern Telegraph Co. for $6,000 unpaid income taxes of that company for each of the years 1940 and 1941. The sole issue is whether the Federal Government is estopped from enforcing such liabilities under the doctrine of res adjudicata by reason of judgments rendered in certain prior litigation.
The facts have been stipulated and are...
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