- 12 - entitlement to capital gain treatment did not stem from any conduct by respondent, equitable estoppel erects no barrier to respondent’s recharacterization of the disputed payment as ordinary income. Additionally, it long has been established that the Internal Revenue Service is not barred by mistakes of its agents from correcting errors of law, “even where a taxpayer may have relied to his detriment on that mistake.” Norfolk S. Corp. v. Commissioner, supra at 60; see also Auto. Club of Mich. v. Commissioner, 353 U.S. 180, 183 (1957); Hedrick v. Commissioner, 63 T.C. 395, 403 (1974). Given that this principle holds true even in dealings with a single taxpayer, it clearly follows that allowance of a treatment contrary to law to one taxpayer does not preclude the Commissioner from correctly applying the law to other taxpayers.3 In conclusion, we emphasize that the Tax Court, as a Federal court, is a court of limited jurisdiction. Commissioner v. McCoy, 484 U.S. 3, 7 (1987); Hays Corp. v. Commissioner, 40 T.C. 436, 442-443 (1963), affd. 331 F.2d 422 (7th Cir. 1964). Consequently, our jurisdiction to grant equitable relief is 3 This is not a situation where two similarly situated taxpayers simultaneously sought official written prefiling rulings, i.e., private letter rulings, from the Internal Revenue Service, and the Internal Revenue Service intentionally chose to treat one differently from the other at the National Office level. See Intl. Bus. Machs. Corp. v. United States, 170 Ct. Cl. 357, 343 F.2d 914 (1965).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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