Administrative Remedies -- Requests for Closing Agreements

The Internal Revenue Code (IRC) at 26 U.S.C. 7121 authorizes the Secretary of the Treasury to enter into a written agreement with any person, or their agent, relating to the liability of that person for any internal revenue tax for any taxable period. Under that authority, TTB has issued regulations at 27 CFR 70.485 pertaining to such “closing agreements.” Specific to this information collection, that regulation requires a taxpayer or their agent to submit a written request to TTB to enter into a closing agreement to resolve excise tax matters. TTB uses the information collected in the request and any attached supporting documentation to determine whether the Bureau should pursue a closing agreement with the taxpayer. Closing agreements allow TTB and a taxpayer to resolve tax liability matters prior to any adversarial legal or administrative proceedings.

The latest form for Administrative Remedies -- Requests for Closing Agreements expires 2027-06-30 and can be found here.