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SECTION 4. PROCEDURES FOR
Internal Revenue Bulletin 2001-40 · 2026-10-03 edition · updated 2026-10-04 · United States
REQUESTING A CLOSING AGREEMENT UNDER TEB VCAP
a. A description of the violation, including its nature, when it occurred and the events surrounding it, and a statement about when and how the issuer discovered the violation; b. The procedures and policies which will be instituted to assure future compliance with the Code; c. That the bond issue is not under examination; d. That the tax-exempt status of the bond issue is not at issue in any court proceeding and is not being considered by the IRS Office of Appeals; e. That, on the issue date, the issuer reasonably expected to comply with section 103 and related provisions of the Code; f. That the violation was not due to willful neglect; g. That the request for a closing agreement was promptly undertaken upon discovery of the violation by the issuer or the conduit borrower; and h. That the payment of the closing agreement amount, if any, will not be made with proceeds of bonds described in section 103(a). (ii) A statement setting forth pro posed closing agreement terms based on the model closing agreement language contained in IRM 7.6.2 and, if applicable, a computation of the proposed closing agreement amount. (iii) The name and phone number of
a person to contact for additional information.
Voluntary Closing Agreement Program for Tax-Exempt Bonds
Notice 2001–60
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