Forwarding to Appellate Sample Clauses

Forwarding to Appellate. 1 An adequate explanation of the closing agreement is prepared by the district examining officer and associated with the examination report. After review of the proposed closing agreement and report by the district office, the agreement, report, and file are forwarded to the regional Appellate Division office which normally considers the protested cases of that district unless the agreement must be signed in the National Office (see section 2.02). 2 When the statutory period of limitation for assessment of tax (if any) for a period involving a closing agreement will expire within a period of 120 days from the date such agreement will be submitted to the regional Appellate Division office for approval, the taxpayer is advised that the closing agreement will not be submitted for approval unless a consent (Form 872 etc.) is signed extending the period of limitation for assessment to a date at least 180 days (at least one year in a case requiring review by the Joint Committe on Internal Revenue Taxation -- see section 601.108 of the Statement of Procedural Rules) from the date such agreement is signed by the taxpayer or a date that will be at least 120 days after the date such agreement is submitted to Appellate, whichever is later. To comply with this requirement, consents may be secured to cover years for which overassessments are proposed.