¶1dissenting:
¶2I believe the claims of the taxpayers should be barred by the doctrine of res judicata and collateral estoppel. I would, therefore, overrule the holding to the contrary in In Re: United Carbon Company Assessment, 118 W.Va. 348, 190 S.E. 546 (1937), and cases that rely on United Carbon disallowing the application of res judicata in these circumstances.