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Settlement Offers and Closing Agreements in CIC Cases Where Appeals has Effected a Settlement

Delegation Order 4-24 settlement authority may be exercised only if all of the following factors are present.

  • The facts surrounding a transaction or taxable event in the tax period under examination are substantially the same as the facts in the settled period;
  • The legal authority relating to such issue must have remained unchanged; 
  • The underlying issue must have been settled by Appeals independently of other issues (e.g. no trading of issues) in the settled tax period; and 
  • The issue must have been settled in Appeals with respect to the same taxpayer (including consolidated and unconsolidated subsidiaries) or another taxpayer who was directly involved in the transaction or taxable event in the settled period.


 

Delegation Order 4-24

IRM 4.46.5.5.3 and 4.46.5.5.4

Page Last Reviewed or Updated: 05-Sep-2013