§ 7121. Closing agreements
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/usc/title-26/section-7121A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
(a)Authorization The Secretary is authorized to enter into an agreement in writing with any person relating to the liability of such person (or of the person or estate for whom he acts) in respect of any internal revenue tax for any taxable period.
(b)Finality If such agreement is approved by the Secretary (within such time as may be stated in such agreement, or later agreed to) such agreement shall be final and conclusive, and, except upon a showing of fraud or malfeasance, or misrepresentation of a material fact—
(1)the case shall not be reopened as to the matters agreed upon or the agreement modified by any officer, employee, or agent of the United States, and
(2)in any suit, action, or proceeding, such agreement, or any determination, assessment, collection, payment, abatement, refund, or credit made in accordance therewith, shall not be annulled, modified, set aside, or disregarded.
(Aug. 16, 1954, ch. 736, 68A Stat. 849; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
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5 references not yet in our index
- Aug. 16, 1954, ch. 736
- 68A Stat. 849
- Pub. L. 94–455, title XIX, § 1906(b)(13)(A)
- 90 Stat. 1834
- Pub. L. 94–455
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§ 7121
Closing agreements
Stat.×12
Fed. Reg.×8
C.F.R.×1
IRM×1
ActAug. 16, 1954, ch. 736
Stat.68A Stat. 849
Pub. L.Pub. L. 94–455, title XIX, § 1906(b)(13)(A)
Stat.90 Stat. 1834
Pub. L.Pub. L. 94–455
Cites 5Cited by 22 across 4 sources