- 6 -
taxpayer to file claim after limitations period had run); Burdett
v. Commissioner, supra. Clearly, if respondent’s representative
advised petitioner that filing for bankruptcy would enable him to
have the deficiency assessment for 1997 discharged, it was an
erroneous statement of law, insufficient to support a claim of
estoppel.
Conclusion
The filing of a Notice of Federal Tax Lien was not an abuse
of discretion by respondent.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011