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.
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-
26 U.S.C. § 7121
AMENDMENTS1976-Subsecs. (a), (b). Pub. L. 94-455 struck out "or his delegate" after "Secretary".
- The term "Secretary" means the Secretary of the Treasury or his delegate.
- The term "person" shall be construed to mean and include an individual, a trust, estate, partnership, association, company or corporation.