Settlement Agreement

ID:
Office:
UILC:
CCA_2010042209124837
---
6224.01-01
Number: 201021023
Release Date: 5/28/2010
From: ---
Sent: Thursday, April 22, 2010 9:12:55 AM
To: ---
Cc: ---
Subject: RE: 870 PTAD or 870 LTAD
These TEFRA forms are the equivalent of closing agreements. The Form 870-PT resolves the partnership-level determination of partnership items and related penalties, but does not resolve partner-level defenses to penalties and affected items.
Part I of the From 870-LT is equivalent to the Form 870-PT. Part II of the Form 870-
LT, however, constitutes a separately executed legal agreement as to the treatment of partner-level defenses to penalties and affected items.
These forms are designed for use for a specific taxable year. If future years are also involved (e.g., future use of basis), a closing agreement should be used instead.