Settlement Agreement

ID: CCA_2011060310542037 Number: 201125038
Release Date: 6/24/2011
Office: ---
UILC: 6224.01-01
From: ---
Sent: Friday, June 03, 2011 10:54:27 AM
To: ---
Cc: ---
Subject: RE: TEFRA partner case
Since the taxpayer signed Part II of the Form 870-LT, he is bound to the determinations in that part as to affected items. If the attached schedule of adjustments reflects a reduction of the losses based on affected items, the losses are conclusively determined based on these limitations. Part II of the Form 870-LT specifically states that it is binding under bother section 7121 and 6224(c). Thus, it has the same binding effect as a closing agreement. See H-Graphics v. Commissioner, T.C. Memo. 1992-345. Nor do we have discretion to abate any paid amounts under section 6404(a).