ROBINSON, District Judge (serving by assignment).
I have studied the record and the briefs submitted in this case. Approaching the issues as they were discussed by counsel, I find the affirmative defense of an equitable estoppel unsupported by the evidence. It seems clear that the taxpayer did not execute Form 870 preliminary to, or with the intention of, making an offer to settle the controversy, nor do I find that the government understood that it was tendered a...
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