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FREDERICKS v. C.I.R.

No. 96-7748.

126 F.3d 433 (1997)

Barry I. FREDERICKS, Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

September 11, 1997.

Attorney(s) appearing for the Case

Barry I. Fredericks (argued), Englewood Cliffs, NJ, for appellant.

Loretta C. Argrett, Assistant Attorney General, Kenneth L. Greene, Karen D. Utiger (argued), Tax Division, Department of Justice, Washington, DC, for appellee.

Before: STAPLETON, LEWIS and ALDISERT, Circuit Judges.

OPINION OF THE COURT

ALDISERT, Circuit Judge.

We must decide whether this is an appropriate case to apply the doctrine of estoppel against the Internal Revenue Service (IRS). Barry I. Fredericks appeals a decision of the United States Tax Court that approved a deficiency assessed by the Commissioner of Internal Revenue in July 1992 for Fredericks' 1977 income tax return. The IRS action requires the taxpayer to pay an additional tax of $28,361 and approximately...

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