122 T.C. No. 7 UNITED STATES TAX COURT JOSEPH DUTTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17802-02. Filed February 11, 2004. P submitted a request for relief from joint and several liability. P subsequently submitted an offer in compromise, which R accepted. Before the offer was accepted, R sent P a letter explaining that it was proposed that P be granted relief under sec. 6015(c), I.R.C., and that P would be entitled to a refund. After accepting the offer, R sent P a notice of determination denying relief from joint and several liability under former sec. 6013(e), I.R.C., and sec. 6015(b), (c), and (f), I.R.C. P petitioned the Court under sec. 6015(e)(1), I.R.C. P argues that the statement that P would be entitled to a refund resulted in a mutual mistake of material fact or misrepresentation sufficient for the offer in compromise to be set aside. For the first time in his answering brief, P argues that the doctrine of equitable estoppel applies.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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