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Boulez v. Commissioner, 76 T.C. 209, 214-215 (1981), affd. 810
F.2d 209 (D.C. Cir. 1987).
One of the elements required for the application of the
doctrine of equitable estoppel is that the person claiming its
benefit must be adversely affected by the acts or statements of
the person against whom an estoppel is claimed. See Kronish v.
Commissioner, 90 T.C. 684, 695-697 (1988); Century Data Sys.,
Inc. v. Commissioner, 86 T.C. 157, 165 (1986). There is no
detrimental reliance on the part of a taxpayer who, pursuant to
the execution of Form 4549, simply pays a tax that was lawful for
the taxpayer to pay. Hudock v. Commissioner, supra at 364.
An additional element required for the application of the
doctrine of equitable estoppel is a false representation or
wrongful misleading silence by the one against whom estoppel is
claimed. Petitioner claims that respondent's agent falsely
represented that the adjustments made on the Form 4549
constituted petitioner's total tax liability. Assuming that
Agent Coar made such a representation, it must be considered in
light of Agent Coar's authority and the scope of Agent Coar's
examination.
Agent Coar's examination involved petitioner's individual
taxes. In issue herein are so-called affected items consisting
of additions to tax for negligence and overvaluation. See N.C.F.
Energy Partners v. Commissioner, supra at 744-746. The TEFRA
rules, codified at sections 6221 through 6233, segregate
adjustments attributable to an individual's interest in a
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