FSL/ET - AD Hoc Closing Agreement Procedures for Walk In Cases/Cases not Under Examination

If a taxpayer, not under examination, approaches FSL/ET field personnel seeking a closing agreement to resolve a prior tax year compliance issue, the matter will be handled by the FSL/ET Closing Agreement (CA) Coordinator. The request for a closing agreement, and any information received from the taxpayer, should be sent by secure email to the CA Coordinator.

The CA Coordinator receives and reviews all written requests for ad hoc closing agreements from taxpayers or representatives who are not under examination

The CA Coordinator will request establishment of a closing agreement case via normal establishment procedures on RCCMS.

The CA Coordinator will complete the “Ad Hoc Walk-In Closing Agreement Initial Memo” explaining the facts, taxpayer’s proposal and voluntary disclosure. The memo will be sent to the FSL/ET Director, Government Entities. The Director will approve or disapprove whether or not the agreement process is the right solution. The Director will provide comments and direction, if necessary.

If the Director has questions or needs additional information not provided in the memo, a conference call will be set up with the CA Coordinator to address the inquiries.

The CA Coordinator will include updates on all ad hoc closing agreements in-process in the FSL/ET Monthly Briefing. The Director will review the Briefing and contact the CA Coordinator if new circumstances arise.

The CA Coordinator will contact the FSL/ET Group Manager if a high profile/sensitive issue arises. The FSL/ET Group Manager will coordinate with the Director as to the direction to take.

If the Director approves the agreement, then the CA Coordinator will work with the taxpayer and/or representative to complete the closing agreement. All files will be uploaded to RCCMS and all case related activity will be recorded on Form 9984, Examining Officer's Activity Record. The Director will receive the closing agreement for approval and signature. The CA Coordinator will follow established procedures to close the case, process the payment and send a copy of the case to the CP&C Monitor. The FSL/ET Group Manager will approve final processing of the case in RCCMS.

If the Director rejects the agreement, then the CA Coordinator will close the case according to established procedures and upload all electronic files received from the taxpayer into the RCCMS case file. Hard-copy documents will be scanned and imported, and the CA Coordinator will record all case-related activity on Form 9984. The FSL/ET Group Manager will approve final processing of the case in RCCMS and annotate Form 9984, Examining Officer's Activity Record.