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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 act
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