TEB - General Rules Applicable to Closing Agreements

Closing agreements are:

Final and conclusive and may not, in the absence of fraud, malfeasance, or misrepresentation of material fact, be reopened as to matters agreed upon or be modified by an officer, employee or examiner of the United States. See IRM 4.81.6.7 for further details.

Subject to Code sections that expressly provide that effect be given to their provisions (including any stated exception for Code section 7122) notwithstanding any other law or rule of law.

Subject to any change in, or modification of, the law enacted after the agreement’s date and that apply to that taxable period(s) when they cover taxable period(s) ending after the closing agreement effective date.