- 12 - 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 In addition to the fact that Tolve is an unpublished opinion that is not precedential, we find the facts of Tolve distinguishable.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 appliedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008