Faramarz and Mitra Elghanian - Page 23

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          and his brother, and that respondent must treat petitioner and              
          his father and brother consistently.  We disagree.                          
               Tax laws must be applied as uniformly as possible.  See                
          Sunday Lake Iron Co. v. Wakefield Tp., 247 U.S. 350 (1918).                 
          However, the Commissioner is not required to offer a settlement             
          to one taxpayer consistent with that offered to other similarly             
          situated taxpayers, absent proof that a taxpayer has been singled           
          out for adverse treatment based on impermissible considerations             
          such as race or religion, and absent contractual agreements to              
          the contrary.  Estate of Campion v. Commissioner, 110 T.C. 165,             
          170 (1998), affd. without published opinion sub nom. Drake Oil              
          Tech. Partners v. Commissioner, 211 F.3d 1277 (10th Cir. 2000),             
          and Tucek v. Commissioner, 198 F.3d 259 (10th Cir. 1999); Norfolk           
          S. Corp. v. Commissioner, 104 T.C. 13, 58-59, supplemented by 104           
          T.C. 417 (1995), affd. 140 F.3d 240 (4th Cir. 1998); Davis v.               
          Commissioner, 65 T.C. 1014, 1022 (1976).                                    
               Petitioners contend that respondent is estopped from denying           
          that petitioner is entitled to deduct expropriation losses in the           
          same amount as respondent allowed for his father and brother.  We           
          disagree.  For estoppel to apply to a party, the other party must           
          have reasonably relied to its detriment on the conduct of the               
          estopped party.  Lyng v. Payne, 476 U.S. 926, 935-36 (1986);                
          Heckler v. Cmty. Health Servs., Inc., 467 U.S. 51, 59 (1984).               
          Petitioner filed his 1986 amended return in 1987, which was                 






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