the government from rescinding the settlement agreement reached by himself and the IRS. Moreover, in the Fourth Circuit, a claimant may not rely upon equitable estoppel to require the United States to take action in violation of a federal statute. See Estate of Hugh S. Hunt v. U.S., 103 Fed. Appx. 475, 477 (4th Cir.2004). Applied to the instant case, this rule means that Wright may not estopp the government from withdrawing the IRS’s settlement agreement. Because Wright’s case was referred to the DOJ prior to his settlement with the IRS, enforcing the settlement would run afoul of the statutory provision authorizing the IRS to compromise tax cases only prior to — not after — their transfer to the DOJ. See 26 U.S.C. § 7122; see also Brooks v. U.S., 833 F.2d 1136, 1145 (4th Cir.1987) (<HOLDING>). Requiring the government to accept the
recognizing offset method recognizing this method holding that where no witness testified in support of a method of calculating consolidated tax savings by determining todays value of past tax savings commissions use of method was improper holding that constructive possession need not be exclusive but may be shared by others holding that section 7122 is the exclusive method by which tax cases may be compromised