KENISON, C. J.
One of today's thorny problems is whether a government or a state should be subject to equitable estoppel when its tax officials seek to collect past taxes based on reversals of rulings that no taxes are due from taxpayers. Atlas, The Doctrine of Estoppel in Tax Cases, 3 Tax Law Rev. 71, 87 (1947). The taxpayer received little comfort from the dictum of Mr. Justice Holmes: "Men must turn square corners when they deal with the Government." Rock Island...
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