Ohendalski v. United States

Summary

The court affirmed dismissal with prejudice of Ohendalski’s tax-refund action because res judicata barred his claims concerning tax liability for the 2002, 2003, and 2004 tax years. It held that the prior Tax Court judgment entered pursuant to settlement was a final judgment on the merits and that the refund claims involved the same cause of action because they arose from the same nucleus of operative facts. The court rejected the argument that the later availability of a statutory refund remedy prevented application of res judicata.