Settlement Agreement

ID:
Office:
UILC:
CCA_2010100615120037
---
6224.01-01
Number: 201101013
Release Date: 1/7/2011
From: ---
Sent: Wednesday, October 06, 2010 3:12:02 PM
To: ---
Cc: ---
Subject: RE: TEFRA Question (closing agreement)
The courts have held that a partnership item settlement under section 6224(c) is, in effect, just a subsection of 7121 that explains how section 7121 operates in the context of a settlement of partnership items.
So either delegation order 97 (closing agreements) or delegation order 4-19 relating to partnership items provide alternative authority for such settlements. ------I am not sure who would constitute a "GS-12 revenue agent reviewer" for this purpose. --- knows. We usually get appeals to execute these in any event.