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misrepresentation. See Heckler v. Community Health Servs., 467
U.S. 51, 61 (1984). While petitioner claims that she relied on
the no change letter for “a sense of security”, there is no
evidence that she changed her behavior or did anything in
reliance on the no change letter, much less that she did anything
to her detriment. See Keaton v. Commissioner, T.C. Memo. 1993-
365; Nadler v. Commissioner, T.C. Memo. 1992-383.
Petitioner’s claims that she relied on the no change letter
in continuing to save her investments, and in continuing to care
for her mother, do not hold water. Petitioner continued to save
her investments and care for her mother after she received the no
change letter in the same ways she did before she received it.
Petitioner’s continued behavior does not establish the change in
position that petitioner must establish in order to prove
reliance. See Heckler v. Community Health Servs., supra at 61.
Petitioner also claims that petitioner relied on the no
change letter in deciding to take custody of her nephew shortly
before June 1998. However, before petitioner took custody of her
nephew, she had signed consents extending the period of
limitations on assessment on November 4, 1995, on October 2,
1996, and on October 14, 1997. Petitioner took custody of her
nephew shortly after respondent issued the notice of deficiency
for this case on April 9, 1998. Since petitioner was aware of
the pending examination of her income tax return for 1992, and
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