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Even if we assume an IRS employee made the statement that
petitioner described, respondent is not bound by that
representation. Petitioners have not shown that they would
suffer unconscionable injury as a result of relying on the
alleged statement. In fact, it appears that from 1996 through
2001, petitioners may have received the benefit of deductions to
which they were not entitled. Furthermore, the IRS employee’s
error, if any, was in a statement of law. Accordingly,
respondent is not estopped from disallowing the claimed
dependency exemption deductions. Respondent’s determination is
sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered under
Rule 155.
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Last modified: May 25, 2011