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Mr. Rivett is correct that closing agreements between a company and the I.R.S. are typically final.
Tax officials acknowledged that I.R.S. procedures require that closing agreements come after an audit, not before.
But later, in a written statement, the I.R.S. said, "There are situations where the timing and use of closing agreements can vary".
I view such closing agreements (although the Division of Taxation may disagree) as "means-tested amnesty" -- collect what you can from people and then let them live their lives.
New Jersey's Division of Taxation is already using installment agreements for those who need time to pay and closing agreements to maximize New Jersey tax collections for those who are unable to pay.
Similar(55)
Close agreements between theoretical and experimental results have been observed.
Close agreements, especially with those of ABAQUS, are achieved.
All PCRs and microarrays results were in very close agreements.
Cameron and Miliband were in close agreement.
WMAP's data are in close agreement with this model, but that agreement is not perfect.
Close agreement is observed.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com