Estate of Marvin E. Greenfield, Deceased, Barbara Greenfield, Personal Representative, and Barbara Greenfield - Page 12




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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          unpublished opinion that is not precedential, we find the facts             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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