Christine A. Dormer - Page 16

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          full with payment of the $4,244.75.  However, even if the parties           
          had in fact agreed to such a resolution, a point which we will              
          address infra, the agreement would not be legally binding.                  
               Petitioner does not contend, nor is there evidence, that the           
          parties complied with the procedures specified under section 7121           
          or 7122 for either a closing agreement or an offer-in-compromise.           
          Rather, petitioner admitted at trial that she did not sign an               
          offer-in-compromise or closing agreement form, and petitioner’s             
          counsel conceded that petitioner was not relying on any argument            
          that an agreement under section 7122 had been reached.                      
          Furthermore, because the relevant negotiations took place in a              
          prepetition setting, any other general theories, such as accord             
          and satisfaction, would be insufficient to create a legally                 
          binding settlement.                                                         
               Nonetheless, the conclusion that the facts here could not              
          support the existence of a legally binding compromise for                   
          $4,244.75 does not end the inquiry.  Petitioner submits on brief            
          that respondent “must be equitably estoppel [sic] from pursuing             
          any further assessments against Ms. Dormer after the June 2002              
          agreement was reached and Ms. Dormer’s settlement check                     
          received.”                                                                  
               Equitable estoppel is a judicial doctrine that operates to             
          preclude a party from denying its own acts or representations               
          that induced another to act to his or her detriment.  Wilkins v.            






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