Settlement Agreement

ID: CCA_2010071909293137 Number: 201030033
Release Date: 7/30/2010
Office: ---
UILC: 6224.01-01
From: ---
Sent: Monday, July 19, 2010 9:29:34 AM
To: ---
Cc: ---
Subject: RE: Question about signing a closing agreement involving a TEFRA entity
If the TEFRA entity is the one paying the tax and being assessed, the agreement has to be signed by a manager under state law of the TEFRA entity on behalf of the entity. I agree that the entity should waive all restrictions on assessment and collection of the specified amounts. In addition, any restrictions under section 6213 and 6225 should be waived. The Tax Matters Partner should also sign if the adjustments are flow through adjustments to the partners under the last sentence of section 6224(c)(1).
---can provide sample language and assist you.