ORDER DENYING GOVERNMENT'S MOTION FOR PARTIAL SUMMARY JUDGMENT
TINDER, District Judge.
May a taxpayer be equitably estopped from prosecuting a tax claim because the taxpayer executed an informal settlement agreement form in which the taxpayer agreed not to dispute the assessment and the government agreed to abate penalties? Yes, in some situations, but not on the facts presented in this matter. The sole question presented is whether equity estops taxpayer...
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