On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of New Capital Fire Inc. v. Commissioner (T.C. Memo. 2021-67). The primary issue presented in New Capital Fire Inc. v. Commissioner was whether the petitioner is barred under the doctrine of equitable estoppel from changing its reporting of its bases in certain assets that the petitioner acquired in the merger because the statute of limitations bars assessment. Dancing the Merger Two Step