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               The doctrine of judicial estoppel focuses on the                        
          relationship between a party and the courts, and it seeks to                 
          protect the integrity of the judicial process by preventing a                
          party from successfully asserting one position before a court and            
          thereafter asserting a completely contradictory position before              
          the same or another court merely because it is now in that                   
          party’s interest to do so.  Edwards v. Aetna Life Ins. Co., supra            
          at 599; Huddleston v. Commissioner, supra at 26.  Whether or not             
          to apply the doctrine is within the court’s sound discretion.  It            
          should be applied with caution in order “to avoid impinging on               
          the truth-seeking function of the court because the doctrine                 
          precludes a contradictory position without examining the truth of            
          either statement.”  Daugharty v. Commissioner, T.C. Memo. 1997-              
          349 (quoting Teledyne Indus., Inc. v. NLRB, 911 F.2d 1214, 1218              
          (6th Cir. 1990)).                                                            
               Because judicial estoppel focuses primarily on the                      
          relationship between a party and the courts, it is                           
          distinguishable from equitable estoppel, which focuses primarily             
          on the relationship between the parties themselves.  Teledyne                
          Indus., Inc. v. NLRB, supra at 1219-1220.  Judicial estoppel                 
          generally requires acceptance by a court of the prior position               
          and does not require privity or detrimental reliance of the party            
          seeking to invoke the doctrine.  Id.; Huddleston v. Commissioner,            
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