asserting the contrary

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Even worse, both the published text and the supplementary material show that Hemingway was, despite the braggadocio of certain passages asserting the contrary, at a low point in his career.
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.