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benefits. Thus, pursuant to section 1.72-15(c)(2), Income Tax
Regs., Mr. Wright’s accident and health benefits are deemed
wholly attributable to his employer’s contributions.
IV. Preclusion of Adjustments in 1999 and 2000 Taxable Years
Petitioners did not specifically articulate the theory on
which they rely to bar respondent from pursuing the deficiencies.
Thus, the Court shall consider laches, equitable estoppel, and
collateral estoppel in light of petitioners’ argument.
A. Doctrine of Laches
Laches is an equitable doctrine which “prohibits a party
from asserting a claim following an unreasonable delay by such
party when there has been a change in circumstances during such
delay which would result in severe prejudice against an opposing
party should the claim be permitted.” Tregre v. Commissioner,
T.C. Memo. 1996-243, affd. without published opinion 129 F.3d 609
(5th Cir. 1997). It is well settled that the United States is
not subject to the doctrine of laches in enforcing its rights.
United States v. Summerlin, 310 U.S. 414, 416 (1940); Guaranty
Trust Co. v. United States, 304 U.S. 126, 132-133 (1938).
Instead, the “timeliness of Government claims is governed by the
statute of limitations enacted by Congress.” Fein v. United
States, 22 F.3d 631, 634 (5th Cir. 1994). Respondent asserted
petitioners’ deficiencies within the period of limitations. Even
though respondent did not seek to adjust petitioners’ 1989, 1994,
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