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or statement of law; (3) ignorance of the true facts by the
taxpayer; (4) reasonable reliance on the act or statement by the
taxpayer; and (5) detriment suffered by the taxpayer because of
the false representation or wrongful, misleading silence.
Norfolk S. Corp. v. Commissioner, 104 T.C. 13, 60 (1995), affd.
140 F.3d 240 (4th Cir. 1998); Megibow v. Commissioner, supra;
Miller v. Commissioner, T.C. Memo. 2001-55. In addition,
estoppel requires at least a minimum showing of some affirmative
misconduct by a Government agent. United States v. Guy, 978 F.2d
934, 937 (6th Cir. 1992). Moreover, equitable estoppel does not
bar or prevent the Commissioner from correcting a mistake of law.
Auto. Club of Mich. v. Commissioner, 353 U.S. 180, 183 (1957);
Schuster v. Commissioner, supra at 317.
Petitioners do not meet the requirements to invoke the
doctrine of equitable estoppel against respondent. At trial, Mr.
Wright testified that he received letters indicating that
respondent was closing audit inquiries on a “no change” basis
regarding the 1989, 1994, 1997, and 1998 taxable years. However,
Mr. Wright did not introduce any of these letters at trial.
Thus, the record is bereft of evidence that respondent made
misrepresentations or misleading statements that would have
engendered any detrimental reliance on the part of petitioners.
Furthermore, petitioners’ reliance on the alleged letters would
be unjustified. Mr. Wright candidly testified that an IRS
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