Authority
The Commissioner may enter into and approve a written closing agreement with any person relating to the liability of such person in respect of any internal revenue tax for any taxable period ending prior or subsequent to the date of such agreement. (IRC 7121)
We may enter in a closing agreement in any case in which:
There appears to be an advantage in having the case permanently and conclusively closed.
The taxpayer demonstrates good and sufficient reasons for desiring a closing agreement.
The Commissioner determines the United States will sustain no disadvantage through consummation of such an agreement.
To enter into and approve a written agreement with any person relating to the internal revenue tax liability of such person (or of the person or estate for whom he or she acts). This does not include the authority to set aside any closing agreement.
This is delegated to Assistant Commissioner (Employee Plans and Exempt Organizations); Division Commissioner (TE/GE); Directors, Employee Plans; Directors, Exempt Organizations; Directors, Government Entities; and Senior Technical Advisors who report directly to the TE/GE Division Commissioner. This authority may also be redelegated to special assistants and division directors reporting directly to the assistant commissioner. 1.2.2.9.3(12)-(13).
