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most favorable to the party opposing summary judgment. See
Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.
Commissioner, 79 T.C. 340, 344 (1982).
Based on our review of the record, we are satisfied that
there is no genuine issue as to any material fact and that
summary judgment may be rendered in respondent’s favor as a
matter of law.
We begin with the well-settled principle that tax deductions
are a matter of legislative grace, and taxpayers must show that
they come squarely within the terms of the law conferring the
benefit sought. See Rule 142(a); INDOPCO, Inc. v. Commissioner,
503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292
U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S. 111, 115
(1933). Petitioners concede that they did not make “other
payments” of $80,000 during 1998, and, therefore, they were not
entitled the refund claimed on their return. The Internal
Revenue Code simply does not provide a tax deduction, credit, or
other allowance for slavery reparations.
For purposes of the pending motion we assume that
petitioners’ assertions regarding the IRS website and their
interview with the special agent are true. Petitioners’
contentions are tantamount to an assertion of equitable estoppel.
Equitable estoppel is a judicial doctrine that precludes a party
from denying its own representations which induced another to act
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