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interest and penalties. Further, in Estate of Raney v.
Commissioner, T.C. Memo. 1992-684, a Form 872-A was deemed to
extend the period of limitations for increased interest under
section 6621.
Petitioners cite Tolve v. Commissioner, 31 Fed. Appx. 73 (3d
Cir. 2002), as authority that the word “tax” does not include
interest or penalties. In addition to the fact that Tolve is an
unpublished opinion that is not precedential, we find the facts
of Tolve distinguishable. In Tolve the Form 872-A included typed
language limiting the amount of any deficiency assessment to that
resulting from six specific items, none of which referenced
additions to tax or interest. Petitioners did not present to
this Court any modifications made to the Form 872-A that the
Greenfields signed.
D. Equitable Estoppel
Petitioners argue that respondent is equitably estopped from
arguing that the period of limitations has not expired. In
support of this argument, petitioners point to respondent’s
failure to include the 1982 tax liability on his proofs of claim
and to Government correspondence addressed to the Greenfields.
Equitable estoppel is a judicial doctrine that operates to
preclude a party from denying that party’s own acts or statements
that induce another to act to his or her detriment. See McCorkle
v. Commissioner, 124 T.C. 56, 68 (2005). It is to be applied
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