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Title 26, Internal Revenue CodeRelease 119-110

§7121 Closing Agreements

Title 26 › Subtitle F — Procedure and Administration › CHAPTER 74 — CLOSING AGREEMENTS AND COMPROMISES › § 7121

Last updated Sep 22, 2026|Official source

Summary

The Secretary can make a written deal with anyone about that person’s liability for any federal tax for any tax period. If the Secretary approves the deal within the time allowed (or later agreed), the deal becomes final. Only fraud, serious wrongdoing, or a false statement about an important fact can undo it. No U.S. official can reopen or change the agreed matters, and courts must not cancel or ignore the agreement or related actions (like assessments, collections, refunds, or credits).

Full Legal Text

Title 26, §7121

Internal Revenue Code, Source: USLM XML via OLRC

(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

Notes & Related Subsidiaries

Editorial Notes

Amendments

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

Reference

Citations & Metadata

Citation

26 U.S.C. § 7121

Title 26, Internal Revenue Code

Last Updated

Sep 22, 2026

Release point: 119-110