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the government is “estopped from challenging its own
correspondence, which claims No Deficiency for 1993 and 1994.”
Petitioners cite no legal authority for their assertions,
and we are unable to find any. Their primary position is
contrary to well-established law. Congress has provided that
closing agreements under section 7121 and compromise agreements
under section 7122 are the exclusive means for the IRS to settle
civil tax disputes with finality. See Botany Worsted Mills v.
United States, 278 U.S. 282, 288 (1929); Estate of Meyer v.
Commissioner, 58 T.C. 69, 70 (1972); see also Sampson v.
Commissioner, 444 F.2d 530, 531 (6th Cir. 1971), affg. T.C. Memo.
1970-212. The record is devoid of any evidence that petitioners
and respondent entered into a valid closing agreement or
compromise agreement.
Petitioners further argue that respondent is estopped from
challenging the letters, which they inaccurately characterize as
stating that they owe “no deficiency” for 1993 and 1994. What
the letters actually purport to address is petitioners’ “account”
for each of the years at issue. The numbers by which peti-
tioners’ “account” was adjusted bear no relationship to those
contained in the statutory notice of deficiency. We would not
expect the account to reflect the amounts that are the subject of
this litigation because the proposed deficiencies and penalties
may not properly be assessed until our decision in this case has
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