Closing Agreements

A closing agreement may relate to any taxable period ending prior or subsequent to the date of the agreement. With respect to taxable periods ended prior to the date of the agreement, the matter agreed upon may relate to the total tax liability of the taxpayer, or it may relate to one or more separate items affecting the tax liability of the taxpayer. With respect to any taxable period ending subsequent to the date of the closing agreement, such agreement is subject to any change in or modification of the law enacted subsequent to the date of execution and applicable to such taxable period and each such agreement shall so recite.