26 U.S.C. § 7121
Closing agreements
# (a) Authorization
The Secretary is authorized to enter into an agreement in writing with any person relating to the liability of such person (or of the person or estate for whom he acts) in respect of any internal revenue tax for any taxable period.
# (b) Finality
If such agreement is approved by the Secretary (within such time as may be stated in such agreement, or later agreed to) such agreement shall be final and conclusive, and, except upon a showing of fraud or malfeasance, or misrepresentation of a material fact— (1) the case shall not be reopened as to the matters agreed upon or the agreement modified by any officer, employee, or agent of the United States, and (2) in any suit, action, or proceeding, such agreement, or any determination, assessment, collection, payment, abatement, refund, or credit made in accordance therewith, shall not be annulled, modified, set aside, or disregarded.
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Cited by 28
- 26 CFR § 1.1071-3 — Reduction of basis of property pursuant to election under section 1071.
- 26 CFR § 1.1071-4 — Manner of election.
- 26 CFR § 1.1082-3 — Reduction of basis of property by reason of gain not recognized under section 1081(b).
- 26 CFR § 1.1311(a)-2 — Purpose and scope of section 1311.
- 26 CFR § 1.1313(a)-2 — Closing agreement as a determination.
- 26 CFR § 1.281-4 — Taxable years affected.
- 26 CFR § 1.355-6 — Recognition of gain on certain distributions of stock or securities in controlled corporation.
- 26 CFR § 1.46-8 — Requirements for taxpayers electing additional one-percent investment credit (TRASOP's).
- 26 CFR § 1.547-2 — Requirements for deficiency dividends.
- 26 CFR § 1.6013-2 — Joint return after filing separate return.
- 26 CFR § 1.6015-1 — Relief from joint and several liability on a joint return.
- 26 CFR § 1.613-7 — Application of percentage depletion rates provided in section 613(b) to certain taxable years ending in 1954.
Show 16 more
- 26 CFR § 1.66-4 — Request for relief from the Federal income tax liability resulting from the operation of community property law.
- 26 CFR § 1.860-2 — Requirements for deficiency dividends.
- 26 CFR § 1.963-6 — Deficiency distribution.
- 26 CFR § 1.992-3 — Deficiency distributions to meet qualification requirements.
- 26 CFR § 20.2001-1 — Valuation of adjusted taxable gifts and section 2701(d) taxable events.
- 26 CFR § 28.2801-5 — Foreign trusts.
- 26 CFR § 301.6225-2 — Modification of imputed underpayment.
- 26 CFR § 301.6404-4 — Suspension of interest and certain penalties when the Internal Revenue Service does not timely contact the taxpayer.
- 26 CFR § 601.201 — Rulings and determinations letters.
- 26 U.S.C. § 1313 — Definitions
- 26 U.S.C. § 547 — Deduction for deficiency dividends
- 26 U.S.C. § 6013 — Joint returns of income tax by husband and wife
- 26 U.S.C. § 6103 — Confidentiality and disclosure of returns and return information
- 26 U.S.C. § 7123 — Appeals dispute resolution procedures
- 26 U.S.C. § 7206 — Fraud and false statements
- 26 U.S.C. § 860 — Deduction for deficiency dividends
Nearby sections (25 sections)
- 6873 · Unpaid claims
- 6901 · Transferred assets
- 6902 · Provisions of special application to transferees
- 6903 · Notice of fiduciary relationship
- 6904 · Prohibition of injunctions
- 6905 · Discharge of executor from personal liability for decedent’s…
- 7001 · Collection of foreign items
- 7011 · Registration—persons paying a special tax
- 7012 · Cross references
- 7101 · Form of bonds
- 7102 · Single bond in lieu of multiple bonds
- 7103 · Cross references—Other provisions for bonds
- 7121 · Closing agreements
- 7122 · Compromises
- 7123 · Appeals dispute resolution procedures
- 7124 · Cross references
- 7201 · Attempt to evade or defeat tax
- 7202 · Willful failure to collect or pay over tax
- 7203 · Willful failure to file return, supply information, or pay tax
- 7204 · Fraudulent statement or failure to make statement to employees
- 7205 · Fraudulent withholding exemption certificate or failure to…
- 7206 · Fraud and false statements
- 7207 · Fraudulent returns, statements, or other documents
- 7208 · Offenses relating to stamps
- 7209 · Unauthorized use or sale of stamps