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See sec. 6221. Respondent examined certain items relating to
Comco for the taxable years 1987 through 1991 and reached
agreement with Mr. Manko and Comco’s other partner on these
items.
The changes to the Comco items required changes to
petitioners’ joint Federal income tax returns for the years at
issue. To facilitate this process, petitioners agreed to extend
the time indefinitely for respondent to assess income taxes for
the years at issue. Petitioners and respondent agreed on the
treatment of the Comco items on petitioners’ returns for the
years at issue and memorialized their agreement on Form 906,
Closing Agreement on Final Determination Covering Specific
Matters (the closing agreement).
The preamble to the closing agreement explains that the
parties wish to determine with finality petitioners’ distributive
share of income, gains, losses, deductions, and credits with
respect to Comco for the years at issue. The final paragraph of
the closing agreement provides that the agreement does not affect
or preclude later adjustments of any item (other than those
relating to Comco) for the years at issue.
When the parties executed the closing agreement, respondent
was also examining petitioners’ returns for the years at issue
for issues unrelated to Comco (the non-Comco items). After the
parties executed the closing agreement, respondent prepared an
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Last modified: May 25, 2011