In general, a revenue procedure is adopted each year to update and confirm the IRS`s general procedures for granting decisions, findings, notices, communications and newsletters to subjects and when entering into agreements on specific issues of interpretation or application of federal tax legislation. The references in the agreement to other provisions of the agreement should be specific. For example, acceptable references “. subject to the provisions of clauses 3 and 7… or . . . provisions of the destination clause (a), before and the destination clause (d) after ,… It is preferable to avoid the use of the “top” and “below” in this context when developing the agreement, since references to provisions that are not on the same page as the reference can be made when the document is in its final form. It should be clear that this is another provision of the agreement and not a provision of another document.

An appropriate reference to this effect could be . . . Schedule 1 of this agreement… The final findings of IRC 7121 tax debt are presented on Form 866, the final determination of tax debt. In cases where the discrepancy on the form is not sufficient to indicate all the periods, taxes and liabilities covered by the agreement, insert “See The Appendix” in this section and insert the information in the same format on a separate sheet shown on the form. All slips must be clearly marked above as “final agreement with (taxpayer name).” See MRI 8.13.1.3.4.2 Conclusion agreements can be made with Form 866 or Form 906, which can be generated by computer. Regardless of how the final agreement is prepared, three copies of the final agreement should be prepared by both the taxpayer and the enforcement officer. If multiple parties are involved, additional copies may be required if all parties want copies with original signatures. Two additional copies of the agreement are required for each additional part.

One of the additional copies will be provided to the additional party (or representative) and the other will be attached to the return of the additional part.

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