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Respondent concedes that because the Forms 872 were signed
by Lobliner and Markowitz on behalf of New Petroleum after it had
merged out of existence, and not on behalf of Energy, they were
invalid. Thus, respondent further concedes that since the notice
of deficiency for Energy's 1985 taxable periods was mailed more
than 3 years after Energy filed its Federal income tax return for
that year, assessment and collection of a deficiency for 1985 are
barred, unless we hold that the last three Forms 872 signed by
Lobliner and Markowitz are valid extensions of the statute of
limitations. Sec. 6501(a).
Generally speaking, equitable estoppel precludes a party
from denying that party's own acts or representations which
induced another to act to the other's detriment. Graff v.
Commissioner, 74 T.C. 743, 761 (1980), affd. per curiam 673 F.2d
784 (5th Cir. 1982). The doctrine of equitable estoppel is based
on the grounds of public policy, fair dealing, good faith, and
justice, and is designed to aid the law in the administration of
justice where without its aid injustice might result. Id. The
elements of equitable estoppel have been variously described, but
for our purposes they may be stated as follows: (1) There must
be a false representation or wrongful misleading silence by the
party against whom the estoppel is claimed; (2) the error must
originate in a statement of fact, not in opinion or a statement
of law; (3) the party claiming the benefits of the estoppel must
have actually and reasonably relied on the acts or statement of
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