IRS Audits Tax Procedure

IRS Closing Agreement Not Binding for “All” Tax Issues

A well drafted closing agreement can provide a level of certainty to an uncertain tax position. The agreements do this by binding the IRS and the taxpayer. They normally include language that says that the agreements are valid for all Federal income tax purposes. In Analog Devices, Inc. v. Commissioner, 147 T.C. 15, the court […]

IRS Audits Tax Procedure

IRS Closing Agreement Valid Even If Not Reviewed by the Joint Committee on Taxation

In AM 20133301F, the IRS addressed the validity of a closing agreement that was not submitted to the Joint Committee on Taxation or JCT for review prior to signing the agreement. The Facts In The Ruling Were As Follows: The taxpayer was an insurance company whose tax returns were being audited by the IRS. The […]