EO Closing Agreement Cases
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
Closing agreements are used to resolve matters that cannot be resolved through normal compliance procedures. Closing agreements encourage future voluntary compliance.
T/Ps must meet certain requirements to qualify for a closing agreement. See procedures for closing agreements in IRM 4.70.14.2.1.3.2, EO – Exempt Organizations Examinations Closing Agreements.
T/Ps may request closing agreements, either during the examination, or by voluntarily contacting the Area Office outside the context of an examination (normally referred to as "walk-in" closing agreements). Walk-in requests must be forwarded to the EO Examinations Closing Agreement Coordinator (Attn: EOCAC) in Mandatory Review.
Examined closing agreements are closed with DC 12 (104) unless a higher priority disposal code applies.
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