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" ... (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 1653
1939
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The Code of Federal Regulations of the United States of America

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...
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The Code of Federal Regulations of the United States of America

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...
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Taxpayer Safeguards: Hearing Before the Subcommittee on Oversight of the ...

United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight - 1983 - 838 páginas
...Secretary (within such time as may be stated in such agreement, or later agreed to) such agreexnent shall be final and conclusive, and, except upon a...be annulled, modified, set aside, or disregarded. Sec 7123. Cross references. (a) Criminal penalties. For criminal penalties for concealment of property,...
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Reports of the Tax Court of the United States, Volume 90

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...
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The Code of Federal Regulations of the United States of America

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...
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Reports of the Tax Court of the United States, Volume 105

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....
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Federal Estate & Gift Taxes: Code & Regulations (Including Related Income ...

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...
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The Code of Federal Regulations of the United States of America

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...
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The Code of Federal Regulations of the United States of America

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...
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Internal Revenue Bulletin, Edições 1-5;Edições 7-17;Edições 19-26

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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