Ezel / IRS Rulings / 200912020

CCA 200912020: Closing agreements generally should not address collection issues

Number
200912020
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
COMPROMISE AND SETTLEMENT: Closing agreement
Topics
Income and deductions
Code sections
§ 7121
Ruling dated
February 19, 2009
Publicly released
March 20, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel addressed whether collection issues belong in a closing agreement. Closing agreements are designed to determine a taxpayer's liability and are final once made. Chief Counsel therefore advised that collection issues generally should not be included in them. The brief email does not describe a particular taxpayer or proposed collection term.

Ruling snapshot

  • Question: Should collection issues be addressed in a closing agreement?
  • Outcome: Advice given: generally, no.
  • Key authorities: Closing-agreement rules under IRC § 7121.

Full text (IRS public release)

ID: CCA_2009021912192652 Number: 200912020
Release Date: 3/20/2009
Office: ----------
UILC: 17.09.00-00

From: --------------------
Sent: Thursday, February 19, 2009 12:19:30 PM
To: --------------------
Cc: -------------------------------------
Subject: Collection issues in closing agreements

As we discussed, closing agreements are designed to determine a taxpayer's liability. They are final and
cannot be changed. Generally, collection issues should not be addressed in closing agreements.

Please call me with any questions.

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