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9th Cir adjudication Administrative Law adopted advice given advice-giving function Advice-giving practice advice-seeker advisory opinions advisory service answer apparent authority application attorneys binding effect Binding the Government Bureau Chapter charge claims collateral estoppel Commissioner concerning Consequently cost Counsel D.C. Cir Davis decision declaratory order discussion district director employee equitable estoppel erroneous advice estopped estoppel fact favorable Federal Register Federal Trade Commission Frozen Food Express furnished give advice Information Act infra Internal Revenue Bulletin Internal Revenue Service interpretations involved issues matter ment Merrill National Office NLRB No-Action Letters oral advice particular Pay Board person practitioners precedential Price Commission private rulings problem Procedural information publicity requirement published ruling questions reason recipient Red Lion regulations relied requests for advice res judicata Selective Service sovereign immunity staff advice letters statute statutory Supp supra Supreme Court taxpayer tion transaction United written advice