Ronald E. Boyer - Page 10

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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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