United States v. RAJMP, Inc.

I. INTRODUCTION

19 There are good and valid reasons why the twin concepts of res judicata and collateral 20 estoppel exist in our system of jurisprudence. The matter adjudged or decided once with 21 all parties fully participating should not again be the subject of dispute. It is wasteful, 22 costly, time consuming, and unnecessary to plow ground that already has been plowed. 23 Multiple and repetitive bites at the apple eventually leave only the core. Here, Defendants 24 have had several opportunities, both procedurally and substantively, to push back and 25 defend against the Government’s efforts to find Robert A. and Joan M. Politte (“Polittes”) 26 as alter egos of RAJMP, Inc. (“RAJMP”). Each time, the Polittes have lost They have lost 27 administratively before the Internal Revenue Service (“IRS”) and judicially before the 28 District and Circuit Courts and the Supreme Court has denied certiorari. And yet, undeterred, or perhaps in denial, the Polittes continue to press the narrative that the alter ego issue remains alive and well and that the apple still has more bites left in it. No, it does not. Upon reviewing and considering the Parties’ moving…