Ryan v. Department of Revenue

The appellants contend, due to the representation of the woman at the commission to the effect that she would file the petition, and due to the appellants’ allegedly justifiable reliance to their detriment upon such representation, that the department is estopped from asserting the untimeliness of the filing of the petition.

We hold that estoppel is inappropriate here because: (1) It is being asserted against the government, and (2) the appellants have failed to establish justifiable reliance on the representation.

With respect to the fact that estoppel is being asserted against the government,…