Employment Tax Closing Agreements

Treas. Reg. 301.7121-1(a) provides that a closing agreement may be entered into in any case in which there appears to be an advantage in having the case permanently and conclusively closed, or if good and sufficient reasons are shown by the taxpayer for desiring a closing agreement and the Commissioner determines that the United States will sustain no disadvantage through consummation of an agreement.

IRM 8.13.1, Closing Agreements, gives instructions and prescribes procedures for Service personnel handling closing agreements entered under IRC 7121.