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equitable powers. Commissioner v. McCoy, 484 U.S. 3, 7 (1987).
However, while we cannot expand our jurisdiction through
equitable principles, we can apply them in the disposition of
cases that are within our jurisdiction. See Woods v.
Commissioner, 92 T.C. 776, 784-787 (1989), and cases cited
therein. The redetermination of a deficiency, addition to tax,
or penalty determined by respondent is within our jurisdiction.
Secs. 6213(a), 6665, 6671. Accordingly, in deciding this issue,
we are not expanding on our statutory jurisdiction.
"[T]he doctrine of equitable estoppel is applied against the
Government `with the utmost caution and restraint.'" Kronish v.
Commissioner, 90 T.C. 684, 695 (1988) (quoting Boulez v.
Commissioner, 76 T.C. 209, 214-215 (1981), affd. 810 F.2d 209
(D.C. Cir. 1987)). There are several conditions that must be
satisfied before the doctrine is applied: (1) A false
representation or wrongful, misleading silence by the party
against whom the opposing party seeks to invoke the doctrine; (2)
error in a statement of fact and not in an opinion or statement
of law; (3) ignorance of the facts; (4) reasonable reliance on
the acts or statements of the one against whom estoppel is
claimed; and (5) adverse effects of the acts or statements of the
one against whom estoppel is claimed. See Kronish v.
Commissioner, supra at 695, and cases cited therein.
Petitioners assert that they were adversely affected in this
case by respondent's failure promptly to notify them of the
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