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Title 26 — Internal Revenue Code

Chapter 74 — Closing Agreements and Compromises

§ 7121. Closing agreements

Statutory text

(a)

Authorization

The Secretary is authorized to enter into an agreement in writing with any person relating to the liability of such person (or of the person or estate for whom he acts) in respect of any internal 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, or later agreed to) such agreement shall be final and conclusive, and, except upon a showing of fraud or malfeasance, or misrepresentation of a material fact—

(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, payment, abatement, refund, or credit made in accordance therewith, shall not be annulled, modified, set aside, or disregarded.

Legislative history

Reconstructed from this section’s Code source credit and amendment notes, resolved against the local Statutes at Large. Editorial notes are evidence, not the law that made the change.

  1. Aug. 16, 1954, ch. 736, 68A Stat. 849 · 68A Stat. 849

    Enacted · 26 U.S.C. § 7121

    Aug. 16, 1954, ch. 736, 68A Stat. 849

    Source evidence

    Code source credit
    Aug. 16, 1954, ch. 736, 68A Stat. 849

  2. Pub. L. 94–455 title XIX § 1906(b)(13)(A) · 90 Stat. 1520

    Struck · 26 U.S.C. § 7121(a); 26 U.S.C. § 7121(b)

    Pub. L. 94–455 struck out “or his delegate” after “Secretary”

    Source evidence

    Code amendment note
    Subsecs. (a), (b). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.

    Enacted provision · exact public law section
    (A) The Internal Revenue Code of 1954, as amended by this Act, is amended by striking out “Secretary or his delegate” each place it appears and inserting in lieu thereof “Secretary”.

1 of 2 references resolved to an enrolled provision · 1 partial

Editorial Notes

Amendments

1976—Subsecs. (a), (b). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.

Credits

1954–1976 · 2 acts
  1. 1954Aug. 16, 1954, ch. 736, 68A Stat. 849
  2. 1976Pub. L. 94–455, title XIX, § 1906(b)(13)(A), , 90 Stat. 1834.
Show as published

(Aug. 16, 1954, ch. 736, 68A Stat. 849; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), , 90 Stat. 1834.)

Parsed from the official OLRC USLM XML in data/usc_all/usc26.xml · release point 119-108 · OLRC build 2026-09-16

USLM identifier /us/usc/t26/s7121