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the misrepresentations to his detriment. Rapp v. United States
Dept. of Treasury, Office of Thrift Supervision, 52 F.3d 1510,
1516 (10th Cir. 1995); The Board of County Commrs. v. Isaac,
supra; Estate of Emerson v. Commissioner, supra at 617-618;
Underwood v. Commissioner, 63 T.C. 468, 477-478 (1975), affd. 535
F.2d 309 (5th Cir. 1976). The detrimental-reliance test includes
the requirement that the party asserting estoppel, as a result of
the misrepresentation, must have been deprived of something to
which it was entitled. Heckler v. Community Health Servs., Inc.,
467 U.S. 51, 61 (1984); Kennedy v. United States, 965 F.2d 413,
418 (7th Cir. 1992).
Respondent, among other things, argues that because
petitioners, for the years before us, were not entitled to the
1975-NOL, petitioners were not deprived of something to which
they were entitled. We agree.
Because the 5-year period for the carryforward of
petitioner's 1975-NOL expired on December 31, 1980, petitioners,
under the law as applicable to 1975, were not entitled to carry
forward the 1975-NOL to 1989, 1990, and 1991, and petitioners
were not deprived of any NOL carryforward to which they were
entitled.
With regard to the $7,414 claimed car and truck expenses and
to the accuracy-related penalties under section 6662(a) for
substantial understatements of income tax for 1989 and 1990,
petitioners have failed to make any separate arguments, and we
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