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Commissioner, 98 T.C. 695, 700 (1992). We have previously denied
estoppel claims of taxpayers based on erroneous abatements or
refunds. See, e.g., Miller v. Commissioner, 23 T.C. 565, 569
(1954), affd. 231 F.2d 8 (5th Cir. 1956); Brown v. Commissioner,
T.C. Memo. 1996-100, affd. without published opinion 181 F.3d 99
(6th Cir. 1999); Wilson v. Commissioner, T.C. Memo. 1991-491;
Beer v. Commissioner, T.C. Memo. 1982-735, affd. 733 F.2d 435
(6th Cir. 1984).
Although we deem it unnecessary to provide an indepth
analysis of the doctrine of equitable estoppel here, we do note
that one of the key elements of an estoppel claim is reasonable
reliance on the acts or statements in question. Greenberg Bros.
Pship. #4 v. Commissioner, 111 T.C. 198, 208 n.16 (1998), affd.
sub nom. Cinema ‘84 v. Commissioner, 294 F.3d 432 (2d Cir. 2002).
Given the fact that: (1) The aggregate deficiencies and additions
to tax determined in the notices exceeded petitioner’s
corresponding remittances by more than $110,000, (2) respondent’s
counsel had previously notified petitioner that assessments had
been made in error and that corrective action would follow to
restore the status quo, and (3) petitioner received no indication
from either respondent’s counsel or this Court that his case had
been resolved, we conclude that petitioner’s reliance on the
erroneous refund and contemporaneous correspondence from
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