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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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