- 10 - 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 hasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011