- 13 - 361-62 (1930). Moreover, even if it were otherwise relevant here, petitioner has presented no evidence of unfair conduct by the IRS, apart from his bald assertion that he relied to his detriment on the closing letter. And there is no showing here that the Commissioner has even sought to reopen petitioner's 1990 liability for tax. We hold that even though the IRS made a mistake of law in respect of petitioner's 1990 return, the Commissioner certainly had the power to correct that mistake as it affected petitioner's 1992 return. 3. Social Security payments The Commissioner's inclusion of petitioner's New York City pension in his gross income increased his adjusted gross income. Such increase resulted, without dispute, in an increase in the amount of taxable Social Security benefits petitioner received. As indicated earlier herein, petitioner does not contest this adjustment if, as we have held, his New York City pension is includable in his gross income. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
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