The Estate of George Batchelor sought federal income-tax refunds arising from a $502 million sale of an aviation company, the related repayment of $41 million in settlement payments, and Batchelor’s 1999 and 2000 returns. In an earlier action, the government had pursued transferee liability for the company’s unpaid corporate taxes; the district court later held that res judicata barred the government from contesting the Estate’s personal income-tax claims. The district court separately ruled for the government on Count III, where the Estate sought income-tax relief for settlement amounts previously taken as an estate-tax deduction. The Eleventh Circuit reversed as to the personal-tax claims and affirmed as to the settlement payments. It held that the earlier transferee-liability action and the refund suit involved different taxpayers, tax liabilities, statutory rights and duties, and factual issues, even though both arose from the same stock transaction. Claim preclusion therefore did not prevent the government from litigating the personal income-tax claims. As to the settlement payments, 26 U.S.C. § 642(g) barred a second deduction unless an exception in § 691(b) applied; § 1341 did not independently create the required deduction, and §§ 162 and 212 did not permit one. The judgment was affirmed in part, reversed in part, and remanded.