Fax Us: (818) 845-6031
Santa Clarita, CA 91355


Closing Agreements

A closing agreement is a final agreement between the IRS and a taxpayer on specific issues or liabilities. Closing agreements can be used to resolve issues under consideration in Examination, Appeals or in Counsel (for non-docketed years).   They will be sometimes used to cover aspects of a settlement not disposed of by a decision in a docketed case, including resolution of disputed issues for years not yet in litigation.    Any issue that is docketed before the US Tax Court, or previously decided by the Tax Court, cannot be changed by a Closing Agreement.Closing agreements are typically not disclosed. However, in a few cases involving tax-exempt organizations, the IRS has made disclosure a condition of entering into a settlement. Examples of where using a Closing Agreement is valuable is in determining depreciable basis of property (land-building allocation), acquisitions (allocation of purchase price to various assets, including goodwill), and so forth.