herself, the collections officer, and the F urisdiction to transfer, “if it is in the interests of justice.” 28 U.S.C. § 1631. In this case, however, the “interests of justice” do not require transfer, because Plaintiffs challenged the assessments for 1997 and 1998 in United States Tax Court, and that court found Plaintiffs liable. Montagne, T.C. Memo. 2004-252. Further, Plaintiffs had an opportunity to challenge the collection actions for 1996, 1998, and 1999 in Tax Court and did so. Montagne v. Comm’r, Docket No. 19709-02L (Sept. 26, 2003). Therefore, the doctrine of res judicata precludes Plaintiffs from now challenging those final judgments in a United States District Court. Parklane Hosiery Co., Inc. v. Shore, 439 U.S. 322, 326 n. 5, 99 S.Ct. 645, 58 L.Ed.2d 552 (1979) (<HOLDING>). Accordingly, because Plaintiffs have had an
holding that res judicata applies when the parties are identical or in privity the first suit proceeded to a final judgment on the merits and the second claim is based on the same set of transactional facts as the first holding res judicata also applies to those in privity with parties holding that an unappealed order is a final judgment on the merits for res judicata purposes holding additional parties in second suit do not prevent the application of res judicata based on the first suit holding that defendant in second suit was in privity for res judicata purposes because his interests were aligned with those of defendant in first suit which concerned same facts