PENNSYLVANIA ET AL.
v.
BOARD OF DIRECTORS OF CITY TRUSTS OF THE CITY OF PHILADELPHIA; AMITY ESTATES, INC., ET AL. V. WERKING; WOLF V. BOYD, DISTRICT DIRECTOR, IMMIGRATION AND NATURALIZATION SERVICE; OLAF PEDERSEN'S REDERI A/S V. MOTOR DISTRIBUTORS, LTD., ET AL.

U.S. | 1957-06-03
Nos. 769; No. 806; No. 822; No. 887
353 U.S. 989 Supreme Court of the United States (1957) Positive Treatment
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  • Bornstein v. The United States, 345 F.2d 558 (Ct. Cl. 1965)
    …ppel does not prevent the Commissioner from changing his position to correct an error of law. The principal case in this area is Automobile Club of Michigan v. Commissioner of Internal Revenue, 353 U.S. 180, 77 S.Ct. 707, 1 L.Ed.2d 746, reh. denied, 353 U.S. 989, 77 S.Ct. 1279, 1 L.Ed.2d 1147 (1957). The Supreme Court there held that the Commissioner of Internal Revenue was not estopped from applying the revocation of a ruling retroactively, since the doctrine of equitable estoppel is not a bar to the corre…

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