William O. Douglas

“ In all cases, therefore, where it is sought to apply the estoppel of a judgment rendered upon one cause of action to matters arising in a suit upon a different cause of action, the inquiry must always be as to the point or question actually litigated and determined in the original action ”

“ Shortly thereafter respondent and the Commissioner filed stipulations in the pending Tax Court proceedings stating that 'there is no deficiency in Federal income tax due' from respondent for the taxable years in question, that the tax liability for each of the years was nil, and that the jeopardy assessment was abated. [1] The Tax Court, pursuant to the stipulation, entered formal decisions that there were no deficiencies for the taxable years in question. The Tax Court, however, held no hearing ”