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not aver specific expenses that respondent failed to allow. In
any event, by the stipulation of settled issues, respondent has
allowed various business (and other) deductions. Those
deductions, however, are not sufficient to reduce to zero the
deficiencies determined for 1995, 1996, and 1997. Nevertheless,
petitioner argues that respondent’s continued assertion of the
deficiencies and additions to tax remaining at issue is not
“fair”, based on respondent’s allegedly misleading actions and
statements in connection with the premature assessments of the
amounts set forth in the notices. Thus, while, in effect,
acknowledging unreported income in excess of the deductions
allowed by respondent for 1995, 1996, and 1997, petitioner does
not want to pay the resulting deficiencies in tax (and section
6654(a) additions to tax), claiming that respondent’s actions led
him to believe that his case had been resolved, thereby prompting
him to discard records that would have substantiated additional
deductions. Although not phrased in so many words, petitioner’s
argument essentially amounts to a claim of estoppel.
Equitable estoppel is a judicial doctrine that precludes a
party from denying that party’s own acts or representations that
induced another to act to his or her detriment. E.g., Graff v.
Commissioner, 74 T.C. 743, 761 (1980), affd. 673 F.2d 784 (5th
Cir. 1982). It is to be applied against the Commissioner only
with utmost caution and restraint. E.g., Hofstetter v.
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