... (1) the case shall not be reopened as to the matters agreed upon or the agreement modified, by any officer, employee, or agent of the United States, and (2) in any suit, action, or proceeding, such agreement, or any determination, assessment, collection,... The Code of Federal Regulations of the United States of America Having ... - Página 16531939Visualização completa - Sobre este livro
| 1972 - 372 páginas
...fraud or malfeasance, or misrepresentation of a material fact — (1) The case shall not be reopened aa to the matters agreed upon or the agreement modified...be annulled, modified, set aside, or disregarded. § 301.7121-1 Closing agreements. (a) In general. The Commissioner may enter into a written agreement... | |
| 1976 - 420 páginas
...final and conclusive, and, except upon a showing of fraud or malfeasance, or misrepresentation oí a material fact: (1) The case shall not be reopened...be annulled, modified, set aside, or disregarded. However, a closing agreement with respect to a taxable period ending subsequent to the date of the... | |
| United States. Tax Court - 1988 - 1424 páginas
...revenue tax for any taxable period. (b) FINALITY.— If such agreement is approved by the Secretary (within such time as may be stated in such agreement,...credit made in accordance therewith, shall not be (753) 761 where there is an agreement as to a specific matter affecting tax liability; a Form 906 closing... | |
| 1993 - 700 páginas
...agreement which is approved within such time as may be stated in such agreement, or later agreed to, shall be final and conclusive, and, except upon a...be annulled, modified, set aside, or disregarded. However, a closing agreement with respect to a taxable period ending subsequent to the date of the... | |
| United States. Tax Court - 1995 - 512 páginas
...be final and conclusive, and, except upon a showing of fraud or malfeasance, or misrepresentation of material fact — (1) The case shall not be reopened...be annulled, modified, set aside, or disregarded. Statutory authority for closing agreements has existed since 1921. Revenue Act of 1921, ch. 136, tit.... | |
| CCH Incorporated, CCH Tax Law Editors - 2008 - 1632 páginas
...appeared. Effective 2-1-77. [Sec. 7121(b)] (b) FINALITY. — If such agreement is approved by the Secretary (within such time as may be stated in such agreement,...be annulled, modified, set aside, or disregarded. Amendments • 1976, Tax Reform Act of 1976 (PL 94-455) PL 94-455, §1906(b)(13)(A): Amended 1954 Code... | |
| 1970 - 364 páginas
...for any taxable period". (b) Finality. If such agreement is approved by the Secretary or his delegate (within such time as may be stated in such agreement,...be annulled, modified, set aside, or disregarded. § 301.7121-1 Closing agreements. (a) In general. The Commissioner may enter into a written agreement... | |
| 1968 - 340 páginas
...for any taxable period. (b) Finality. If such agreement is approved by the Secretary or his delegate (within such time as may be stated in such agreement,...be annulled, modified, set aside, or disregarded. § 301.7121-1 Closing agreements. (a) In general. The Commissioner may enter into a written agreement... | |
| United States. Internal Revenue Service - 1960 - 1384 páginas
...any taxable period. (b) FINALITY.— If such agreement Is approved by the Secretary or his delegate (within such time as may be stated in such agreement,...be annulled, modified, set aside, or disregarded. §301.7121-1 CLOSING AGREEMENTS. — (a) In general. — The Commissioner may enter into a written... | |
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