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would suffer unconscionable injury as a result of relying on
respondent’s acceptance of the previously filed returns.
Furthermore, respondent’s error, if any, was in a statement of
law. We therefore conclude that respondent is not estopped from
asserting a deficiency for 2003 with respect to the Social
Security benefits. Respondent’s determination is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011