Charles and Beatrice M. Reynolds - Page 10




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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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