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written communications from respondent that alerted petitioner to
the possibility of future adjustments. Thus, the Court would be
hard pressed to find even misleading silence, much less
affirmative misconduct. The statements regarding adjustments
likewise call into question whether reliance by petitioner on
$4,244.75 as a “final payoff figure” was reasonable in any event.
The Court concludes that the circumstances of this case are not
such as to warrant application of equitable estoppel.
The matter at bar presents a scenario where the objective
evidence and the governing settlement document show that the
parties reached agreement as to the resolution of specified
components of petitioner’s liabilities for the 1998 taxable year.
Petitioner’s understanding that the bargain encompassed all
amounts due for 1998 was at most a unilateral mistake, a belief
that the agreement contained a larger promise by respondent than
in fact it did, which would not support a reformation or other
form of relief. Although we sympathize with petitioner’s
position, controlling law affords no basis upon which we may
enforce a complete settlement of petitioner’s 1998 liabilities
for $4,244.75.
Accordingly, in absence of an enforceable settlement of all
1998 liabilities, it cannot be said that an error, ministerial or
otherwise, was committed in computing the balance due on
petitioner’s account. Furthermore, petitioner has not so much as
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