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Internal Revenue Code · 26 U.S.C.

§ 7121. Closing agreements

In force Text current through Public Law 119-121 (October 9, 2026) release point 119-121

Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).

Cite as 26 U.S.C. § 7121

At a glance

Read from the text, the source credit and the official notes. Not part of the law.

Status
In force
Enacted
October 4, 1976 by Pub. L. 94–455
Length
2 subsections · 171 words · about 1 min to read
(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.

(Aug. 16, 1954, ch. 736, 68A Stat. 849; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)

Regulations under this section

Treasury regulations (26 CFR) issued under § 7121

Cross-references

Computed from the citations in the text of Title 26 and 26 CFR.

Cited by 7 Code sections

Cited in 20 regulations not issued under it

Amendment history

From the source credit and the official notes, newest first.

  1. Enacted by Pub. L. 94–455Parts changed in 1976: (a)

Where it sits in the Code

  1. Subtitle F Procedure and Administration
  2. Chapter 74 CLOSING AGREEMENTS AND COMPROMISES

Nearby sections

Official notes

Show the Law Revision Counsel's notes (amendments, effective dates)

Editorial Notes

Amendments

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