Closing Agreements

Tax-exempt organizations may want to enter into a closing agreement to resolve tax liability issues with finality.

Generally, an exempt organization may initiate a closing agreement by sending a letter
to the appropriate area office. The letter must contain the following information:

4.75.25.1 EO Examinations Closing Agreement Overview

4.75.25.2 Glossary of Terms

4.75.25.3 Supplemental Guidance

4.75.25.4 Authority

4.75.25.5 Finality of Closing Agreements

4.75.25.6 Application of Closing Agreements

4.75.25.7 Multiple Closing Agreements

4.75.25.8 Role of Area Counsel

4.75.25.9 Team Examination Program (TEP) Cases

4.75.25.10 EO Examinations Closing Agreement Coordinators

4.75.25.11 Recognition of Exempt Status

4.75.25.12 Development Prior to Considering A Closing Agreement

4.75.25.13 Taxpayer Request to Enter into A Closing Agreement

4.75.25.14 Drafting Closing Agreements

4.75.25.15 Approval of Draft Closing Agreement

4.75.25.16 Final Approval Signatures

4.75.25.17 Approval and Execution of Closing Agreement

4.75.25.18 Tax Assessments

4.75.25.19 Closing Agreement Package

4.75.25.20 Coordinator Follow-up Responsibilities

4.75.25.21 Monitoring Reports

Exhibit 4.75.25-1 EO Closing Agreement Approval Cover Sheet

Exhibit 4.75.25-2 Sample Closing Agreement as To Final Determination

Exhibit 4.75.25-3 Certification by Receiving And Reviewing Officials

Exhibit 4.75.25-4 Cover Memorandum - Payment to Service Center

Exhibit 4.75.25-5 Transmittal Memorandum to Director, EO Examinations

Exhibit 4.75.25-6 Transmittal Letter to Taxpayer

Exhibit 4.75.25-7 Transmittal Letter to Taxpayer's Representative

Exhibit 4.75.25-8 Disclosure Statements

Exhibit 4.75.25-9 Follow-up Action Memorandum to Closing Agreement Coordinator

Exhibit 4.75.25-10 EO Closing Agreement Quarterly Report

Internal Revenue Manual 4.75.25, Exempt Organizations Examination Procedures, Exempt Organizations Closing Agreements

DISCLAIMER: This information is not intended to provide legal or accounting advice,
or to address specific situations. Please consult with your legal or tax advisor to supplement and verify what you learn here.