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Partial Agreements

Partial agreements should be considered and entered into where the taxpayer agrees with one or more, but not all, proposed issues. The interest will stop on the amount of any deficiency that is agreed and paid. A partial agreement requires the taxpayer to execute a waiver of restrictions (Form 870) covering the agreed issue(s). Partial agreements limit the number of adjustments Appeals will consider thereby expediting the Appeals’ process. Appeals will not reopen any issue covered by a partial agreement. It should be noted there are cases excluded from partial agreement procedures. Such cases include those docketed in the United States Tax Court and cases involving issues that, if resolved in taxpayer’s favor, would produce overpayments in excess of $2,000,000 subject to review by the Joint Committee.

Page Last Reviewed or Updated: 06-Nov-2014