Son of Boss Settlement Initiative FAQs - Section 4(c), Required Procedures for Electing Participants: Closing Agreement and Payment


Notice: Historical Content

This is an archival or historical document and may not reflect current law, policies or procedures.

Q-4c.1. After submission by the taxpayer of an election to participate in the settlement resolution, when should the revenue agent mail a notification to the taxpayer and a request for additional information or documents?    

A-4c.1. The revenue agent should mail the notification to the taxpayer as soon as possible, but generally not later than 10 business days after receipt of the taxpayer election. This notification will include all the applicable forms the taxpayer is required to complete within the 60-day timeframe.

Q-4c.2. Under what circumstances will the Service grant an extension to the taxpayer to submit the signed closing agreement?
A-4c.2. The announcement allows the taxpayer 30 days for submission. Only under unusual circumstances will this extension be granted. Any extensions granted must be approved by the revenue agent’s manager. Extensions will not be automatic and the taxpayer must explain to the satisfaction of the Service the reasons an extension is being requested. The Service has the discretion to grant or to refuse an extension.

Q-4c.3. The announcement requires either full payment at the time of signing the closing agreement or that the electing taxpayer make other arrangements. How do I make other arrangements if I cannot make full payment?

A-4c.3. At the time a taxpayer submits their signed closing agreement, if the taxpayer does not make payment, the taxpayer must submit complete financial statements. The taxpayer will be referred to a Collection Officer who will determine, within 30 days, the taxpayer’s eligibility for other payment arrangements. Once the alternative payment arrangements are finalized, the closing agreements will be executed and assessment will be made. Failure to reach acceptable financial arrangements will make the taxpayer ineligible to participate in this settlement initiative. 

Q-4c.4. Once a taxpayer has submitted all required forms within the 60 days, when can the taxpayer expect to receive the revenue agent’s report and closing agreement?

A-4c.4. The revenue agents will generally review the documents provided and prepare a report and closing agreement for the taxpayer’s signature within 30 days of receipt of the completed forms.

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