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Attached to the December 21, 1989, letter is a Sample Language for
Closing Agreement (Form 906) which states in relevant part:
WHEREAS, the taxpayer(s) and the
Commissioner wish to determine with finality
all of the federal income tax consequences of
the taxpayer's(s') interest in the
partnership(s) for all taxable years;
NOW IT IS HEREBY DETERMINED AND AGREED
for Federal income tax purposes that:
* * * * * * *
10. * * * no additions to the tax or
penalties shall be imposed with respect to the
taxpayers' interest in the partnership(s),
including the additions and penalties
described in I.R.C. sections 6653, 6659, and
6661.
A "netting" provision was also included in the sample closing
agreement.
On December 22, 1989, Mr. Kletnick replied to Mr. Nolan's
letter, stating: "With respect to your letter dated December 21,
1989, as we discussed, our office has forwarded the proposed revised
closing agreement to the National Office and, subject to
administrative approval, we expect its issuance in the next few
days."
Respondent entered into closing agreements with many Arbitrage
Management partners. Respondent, however, refused to enter into a
closing agreement with petitioner with regard to any relevant year
(i.e., 1978, 1979, 1980, 1981, 1982, or 1983).
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