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Internal Revenue Service that the Plan, clearly labeled a pension
plan, contained a section dealing with disability. Second, the
determination letter does not purport to deal with the taxability
to plan participants of distributions made under the plan.
Third, petitioners have failed to show any reliance on the
determination letter, that any such reliance would have been
reasonable, or that they were damaged on account of such
purported reliance. “Although the doctrines of estoppel and
quasi-estoppel are applicable against the Commissioner, it is
well established that these doctrines should be applied against
him with utmost caution and restraint.” Estate of Emerson v.
Commissioner, 67 T.C. 612, 617 (1977) (citations omitted). This
is not an occasion for such application. Furthermore, respondent
has done nothing to revoke her determination letter, and, even if
she had, petitioners have failed to show reliance or other
grounds to challenge such revocation.
IV. Conclusion
The plan distributions constitute gross income to
petitioner. Respondent’s determinations of deficiencies are
sustained.
Decision will be entered
for respondent.
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Last modified: May 25, 2011