Internal Revenue Service, Treasury § 301.7122–1Closing Agreement • March 4th, 2021
Contract Type FiledMarch 4th, 2021Example. A owns 500 shares of stock in the XYZ Corporation which he purchased prior to March 1, 1913. A is considering selling 200 shares of such stock but is uncertain as to the basis of the stock for the purpose of com- puting gain. Either prior or subsequent to the sale, a closing agreement may be entered into determining the market value of such stock as of March 1, 1913, which represents the basis for determining gain if it exceeds the adjusted basis otherwise determined as of such date. Not only may the closing agree- ment determine the basis for computing gain on the sale of the 200 shares of stock, but such an agreement may also determine the basis (unless or until the law is changed to require the use of some other factor to deter- mine basis) of the remaining 300 shares of stock upon which gain will be computed in a subsequent sale.
Internal Revenue Service, Treasury § 301.7122–1Closing Agreement • December 2nd, 2014
Contract Type FiledDecember 2nd, 2014Example. A owns 500 shares of stock in the XYZ Corporation which he purchased prior to March 1, 1913. A is considering selling 200 shares of such stock but is uncertain as to the basis of the stock for the purpose of com- puting gain. Either prior or subsequent to the sale, a closing agreement may be entered into determining the market value of such stock as of March 1, 1913, which represents the basis for determining gain if it exceeds the adjusted basis otherwise determined as of such date. Not only may the closing agree- ment determine the basis for computing gain on the sale of the 200 shares of stock, but such an agreement may also determine the basis (unless or until the law is changed to require the use of some other factor to deter- mine basis) of the remaining 300 shares of stock upon which gain will be computed in a subsequent sale.