- 12 -
Warner v. Commissioner, supra at 2 (“the Commissioner, confronted
by millions of returns and an economy which repeatedly must be
nourished by quick refunds, must first pay and then look. This
necessity cannot serve as the basis of an ‘estoppel’.”); see,
e.g., Brown v. Commissioner, T.C. Memo. 1996-100, affd. 181 F.3d
99 (6th Cir. 1999); Wilson v. Commissioner, T.C. Memo. 1991-491.
We therefore reject petitioners’ estoppel claim in the instant
case.
Conclusion
We have considered all of the other arguments made by
petitioners, and, to the extent that we have not specifically
addressed them, we conclude that they are without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issues,
Decision will be entered
for respondent.
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