Title 26 — Internal Revenue CodeRelease 119-73not60
§7121 Closing Agreements
Title 26 › Subtitle Subtitle F— Procedure and Administration › Chapter 74— CLOSING AGREEMENTS AND COMPROMISES › § 7121
Summary
The Secretary can make a written agreement with anyone about how much internal revenue tax they owe for any tax period. If the Secretary approves the agreement within the time the agreement says (or a later time both agree), the agreement is final. It can only be undone for fraud, serious wrongdoing, or lying about an important fact; otherwise government officials and courts must not reopen, change, or cancel it.
Full Legal Text
Title 26, §7121
Internal Revenue Code — Source: USLM XML via OLRC
(a)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)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
Apr 5, 2026
Release point: 119-73not60