What Is An Irs Closing Agreement

The special file is a temporary file for all documents relating to the contract of conclusion. A Manila folder is used for this file. The exterior of the file is marked by the SPECIAL FICHIER and reflects the taxpayer`s name, the number of closing agreements and the symbols of the branch that handles the case. After signing, the closing agreement with the special file is returned to the original office. The original conclusion contract is copied and the corresponding deletions are carried out in accordance with CCDM 37.1.2.2 guidelines. The letter of transmission of the double concluding contract and copy 6110 of the letter addressed to the subject and the memorandum of transmission from triple to box are signed and dated. A copy of each of the following points is also sent with the triple declaration of the final contract: request for a decision by correspondence, if applicable, and request for final agreement, corresponding decision, if any, and letter of transmission to the subject. The original contract of conclusion and a copy of the corresponding decision, the letter of transmission addressed to the subject and the memorandum of sending to the original office are retained. In accordance with Section 7121 and its regulations, the Commissioner may enter into and approve with any person a written final agreement relating to that person`s liability for an internal income tax for a tax period that ends before or after the date of the agreement. If the proposed letter is to be accompanied by a concluding agreement, the letter and final agreement must be sent jointly for review. The language must be inserted into the letter in which the subject is informed of the contract execution procedure and referred for approval to the head of the competent associate board or to the Counsel/Associate Division (TEGE). See CCDM 32.3.4.7.3 Instructions to Taxpayers on the implementation of agreements and referral of agreements to the Associated Agency. The letter is usually prepared for the signature of the person who approves and signs the closing agreement.

See CCDM 32.3.4.2 Authority.


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