asserting the contrary

References in periodicals archive ?
When these requirements are met, the IRS may treat the previous (mis)representation as true, even if it is not, and the taxpayer is estopped from asserting the contrary (albeit correct) position; see, e.
that the taxpayer was engaged in racketeering, placed the taxpayer in the same position as his co-defendants who were convicted of RICO violations--for tax purposes, in the business of racketeering--and that the IRS was, therefore, estopped from asserting the contrary.