- 10 - period for collection expires. Sec. 301.6325-1(a)(1), Proced. & Admin. Regs. Because the tax was not paid in full, nor did the statutory period for collection expire, petitioner’s 1986 and 1987 tax liabilities were not extinguished. We also note that section 6325(f)(2), by its terms, allows the Commissioner to revoke a certificate of tax lien release where, as in this case, it was issued “erroneously or improvidently” and to reinstate the lien. This provision, which allows respondent to reinstate the lien, belies petitioner’s argument that the erroneously issued certificate in this case extinguished his liability once and for all. B. Equitable Estoppel Argument Petitioner next contends that even if the RFTL did not extinguish the tax liability, respondent is otherwise equitably estopped from collecting his 1986 and 1987 tax liabilities. Petitioner argues that respondent’s conduct over an extended period of time led petitioner to believe that respondent had stopped collection action and therefore petitioner no longer had any tax liability for 1986 or 1987. Equitable estoppel is a judicial doctrine that requires a finding that the taxpayer relied on the Government’s representations and suffered a detriment because of that reliance. Estoppel precludes a party from denying its own representations if those representations induced another to actPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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