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estoppel, or some combination of the two. For completeness, we
shall summarize why neither doctrine is applicable here.
Equitable estoppel is a judicial doctrine that operates to
preclude a party from denying its own acts or representations
that induced another to act to his or her detriment. Wilkins v.
Commissioner, 120 T.C. 109, 112 (2003); Hofstetter v.
Commissioner, 98 T.C. 695, 700 (1992). In tax contexts,
equitable estoppel will be applied against the Government only
with the utmost caution and restraint and upon the establishment
of prerequisite elements: (1) A false representation or
wrongful, misleading silence by the party against whom the
estoppel is claimed; (2) an error in a statement of fact and not
in an opinion or statement of law; (3) ignorance of the true
facts by the taxpayer; (4) reasonable reliance by the taxpayer on
the acts or statements of the one against whom estoppel is
claimed; and (5) adverse effects suffered by the taxpayer from
the acts or statements of the one against whom estoppel is
claimed. Wilkins v. Commissioner, supra at 112; Norfolk S. Corp.
v. Commissioner, 104 T.C. 13, 60 (1995), affd. 140 F.3d 240 (4th
Cir. 1998); see also Lignos v. United States, 439 F.2d 1365, 1368
(2d Cir. 1971).
Here, the record fails to show the existence of any of the
required elements for equitable estoppel. Petitioner does not
identify, nor do we perceive, any particular statements or
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