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HOOVEN & ALLISON CO. v. LINDLEY

No. 82-559.

4 Ohio St. 3d 169 (1983)

HOOVEN & ALLISON COMPANY, APPELLANT AND CROSS-APPELLATE, v. LINDLEY, TAX COMMR., APPELLEE AND CROSS-APPELLANT.

Supreme Court of Ohio.

Decided April 20, 1983.

Attorney(s) appearing for the Case

Messrs. Jones, Day, Reavis & Pogue, Mr. Michael A. Nims, Mr. Kenneth E. Updegraft, Jr., and Mr. Charles H. Moellenberg, Jr., for appellant and cross-appellee.

Mr. Anthony J. Celebrezze, Jr., attorney general, and Mr. Richard C. Farrin, for appellee and cross-appellant.

Per Curiam.

In the case at bar, this court must first decide whether the doctrine of collateral estoppel bars the commissioner from imposing an advalorem property tax upon imported raw goods stored by Hooven in its warehouse.

In Montana v. United States (1979), 440 U.S. 147, the United States Supreme Court clearly set forth the operational features of the interrelated doetrines of res judicata...

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