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SECTION 5. CLOSING AGREEMENT
Internal Revenue Bulletin 2001-40 · 2026-10-03 edition · updated 2026-10-04 · United States
TERMS
Closing agreements under TEB VCAP will generally follow the model closing agreement in IRM 7.6.2. Specific closing agreement terms will depend on the facts and circumstances of the case, including
the degree of diligence exercised by the issuer and any conduit borrower. Any standardized closing agreement terms that are developed for TEB VCAP will be set forth in the Internal Revenue Manual and/or other published guidance.
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