CCA 201028033
Settlement Agreement
ID: CCA_2010060911222137 Number: 201028033
Release Date: 7/16/2010
Office: ---
UILC: 6224.01-01
From: ---
Sent: Wednesday, June 09, 2010 11:22:24 AM
To: ---
Cc: ---
Subject: RE: Rejected agreements
We could have cosigned the original Form 870-PT and it would have been binding on the beneficiaries, even if the pass-thru partner is a grantor trust or otherwise treated as a disregarded entity. I don't think we can sign the copy since our actions in returning the original constituted a rejection of the taxpayer's offer to settle. We will have to wait for the original to be returned in order to sign it.
Without seeing the Form 4549 I cannot say whether that would provided an independent basis for making the assessment.
Source: view the official PDF
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