IRS Closing Agreement Not Binding for “All” Tax Issues
A well drafted closing agreement can provide a level of certainty to an uncertain tax position. The agreements do this by binding the IRS and the taxpayer. They normally include language that says that the agreements are valid for all Federal income tax purposes. In Analog Devices, Inc. v. Commissioner, 147 T.C. 15, the court […] The post IRS Closing Agreement Not Binding for “All” Tax Issues appeared first on Houston Tax Attorney.
Source: Houston Tax Attorney