§ 7121. — Closing agreements.
[Laws in effect as of January 7, 2003]
[Document not affected by Public Laws enacted between
January 7, 2003 and December 19, 2003]
[CITE: 26USC7121]
TITLE 26--INTERNAL REVENUE CODE
Subtitle F--Procedure and Administration
CHAPTER 74--CLOSING AGREEMENTS AND COMPROMISES
Sec. 7121. Closing agreements
(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,
Sec. 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
Amendments
1976--Subsecs. (a), (b). Pub. L. 94-455 struck out ``or his
delegate'' after ``Secretary''.
Section Referred to in Other Sections
This section is referred to in sections 547, 860, 1313, 6013, 6015,
6103, 7123, 7206 of this title.
