Fabio
76b8ec33a7
Ingested titles 12–51 and 54 from OLRC USLM XML @119-100 (the whole Code now, uniform edition; Title 53 is reserved/empty). LegalText 11,221 -> 59,740; repo total 105,704 records. Deterministic (byte-identical rerun, verified on Title 42's 8,356 sections); make check green. make legal-us-code default now covers every title. Co-Authored-By: Claude Opus 4.8 <noreply@anthropic.com>
48 lines
2.1 KiB
Markdown
48 lines
2.1 KiB
Markdown
---
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type: "LegalText"
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title: "26 U.S.C. § 7121"
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description: "Closing agreements"
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jurisdiction: "us"
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corpus: "united_states_code"
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kind: "code_section"
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title_number: 26
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title_name: "INTERNAL REVENUE CODE"
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chapter_number: "74"
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chapter_name: "CLOSING AGREEMENTS AND COMPROMISES"
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section: "7121"
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citation: "26 U.S.C. § 7121"
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status: "current"
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release_point: "119-100"
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release_date: "2026-06-26"
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source: "official"
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source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
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source_identifier: "/us/usc/t26/s7121"
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source_file: "data/legal/raw/us/code/title-26/usc26.xml"
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source_hash: "1fa6a4de4385d2bf8681506e591f87e651a726e36e91320a4e83f2c078a31a6d"
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raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
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text_hash: "e4a23b958ea1150de45ff7c845cff9cf1241a424dc1cdb985536c3b5a0209c51"
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retrieved_at: "2026-07-04"
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confidence: "official"
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tags: ["legal", "us-code"]
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---
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# 26 U.S.C. § 7121 - Closing agreements
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## Text
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(a) Authorization 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.
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(b) Finality 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—
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(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
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(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.
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(Aug. 16, 1954, ch. 736, 68A Stat. 849; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
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## Notes
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Editorial Notes
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Amendments1976—Subsecs. (a), (b). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.
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