Form 870 definition

Form 870 means Internal Revenue Service Form 870, Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment, any successor thereto, and any similar form used for state or local Tax purposes.
Sample 1Sample 2Sample 3

Examples of Form 870 in a sentence

  • If the taxpayer does agree with the proposed changes, the examiner will invite the taxpayer to execute either Form 870 or another appropriate agreement form.

  • Example 2: The Taxpayer and the IRS have multiple audit issues for taxable year 2018 and they decide to resolve their issues by entering into a bilateral settlement agreement using a Form 870- AD on November 10, 2020.

  • The signing of a Federal Form 870 or other IRS form consenting to the deficien- cies, accepting any over assessment shown on the form, or both.

  • If the taxpayer chooses the appeals conference and reaches an agreement with the IRS there, the taxpayer can then sign the Form 870.

  • If the taxpayer agrees to the proposed changes, the taxpayer signs an agreement form (Form 870) and pays the additional tax owed (or receives the proposed refund).

  • Assume that X and Y are United States corporations; that X is in the business of rendering engineering services; that in 1968 the district director proposes to adjust X’s income for 1966 to reflect an arm’s length fee for the rendition of engineering services by X in 1966 relating to the construction of Y’s factory; that X consents to an assess- ment reflecting such adjustment by exe- cuting a Waiver, Form 870; and that an as- sessment of the tax with respect to such ad- justment is made in 1968.

  • Assume that in 1968 the district director proposes to adjust X’s income for 1966 to reflect an arm’s length rental charge for Y’s use of X’s tangible property in 1966; that X consents to an assessment reflecting such adjustment by executing a Waiver, Form 870; and that an assessment of the tax with respect to such adjustment is made in 1968.

  • Assume that X is a U.S. tax- payer and Y is a foreign taxpayer not en- gaged in a trade or business in the United States; that in 1968 the district director pro- poses to adjust X’s income for 1966 to reflect an arm’s length interest charge on a loan made to Y; that X consents to an assessment reflecting such allocation by executing a Waiver, Form 870; and that an assessment of the tax with respect to such adjustment is made in 1968.

  • The final decision of the In- ternal Revenue Service for purposes of this section is the document which re- solves the tax liability of the taxpayer with regard to all tax, additions to tax and penalties at issue in the adminis- trative proceeding (such as a Form 870 or closing agreement), or a notice of assessment for that liability (such as the notice and demand under section 6303), whichever is earlier mailed, or otherwise furnished, to the taxpayer.

  • If the taxpayer chooses to go to the appeals conference and reaches an agreement with the IRS at the appeals conference, the taxpayer can then sign the Form 870.

Related to Form 870

  • Section 338 Forms has the meaning set forth in Section 6.5(d).

  • Tax Return means any return, declaration, report, claim for refund, or information return or statement relating to Taxes, including any schedule or attachment thereto, and including any amendment thereof.

  • Form 10 means the registration statement on Form 10 filed by SpinCo with the SEC to effect the registration of SpinCo Shares pursuant to the Exchange Act in connection with the Distribution, as such registration statement may be amended or supplemented from time to time prior to the Distribution.

  • IRS means the United States Internal Revenue Service.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Income Tax Return means any Tax Return relating to Income Taxes.

  • Form 8-K As defined in the Pooling and Servicing Agreement.

  • Short Form Notice means the Short Form Notice substantially in the form as

  • Rule 482 Statement means a document that contains the number of Securities issued, the offering price and any other items dependent upon the offering price, prepared in accordance with the provisions of Rule 482 of the 1933 Act, a copy of which shall be attached as Schedule D hereto. “Statutory Prospectus” as of any time means the prospectus relating to the Securities that is included in the Registration Statement immediately prior to that time, including any document incorporated by reference therein. Each preliminary prospectus and the prospectus filed as part of the effective Registration Statement or as part of any amendment thereto, or filed pursuant to Rule 497 under the 1933 Act, complied when so filed in all material respects with the Rules and Regulations and each preliminary prospectus and the Prospectus delivered to the Underwriters for use in connection with this offering was identical to the electronically transmitted copies thereof filed with the Commission pursuant to XXXXX, except to the extent permitted by Regulation S-T. If a Rule 462(b) Registration Statement is required in connection with the offering and sale of the Securities, the Fund has complied or will comply with the requirements of Rule 111 under the 1933 Act Rules and Regulations and Rule 3a of the Commission’s Internal and Other Procedures (“Rule 3a”) relating to the payment of filing fees thereof. The Fund, subject to the Registration Statement having been declared effective and the filing of the Prospectus under Rule 497, has taken all required action under the 1933 Act, the 1940 Act, the Securities and Exchange Act of 1934, as amended (the “1934 Act”) and the Rules and Regulations to make the public offering and consummate the sale of the Securities as contemplated by this Agreement.

  • Listing Statement means this listing statement of the Corporation, including the schedules hereto, prepared in support of the listing of the Common Shares on the CSE.

  • Internal Revenue Service means the United States Internal Revenue Service.

  • Monthly Form 8-K As defined in Section 3.22(a).

  • UCC Filing Authorization Letter means a letter duly executed by each Loan Party authorizing the Collateral Agent to file appropriate financing statements on Form UCC-1 without the signature of such Loan Party in such office or offices as may be necessary or, in the opinion of the Collateral Agent, desirable to perfect the security interests purported to be created by each Security Agreement and each Mortgage.

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.

  • Case Report Form means a printed, optical or electronic document or database designed to record all of the information, which is required by the Protocol to be reported to the Sponsor on each Study Participant.

  • Tax return preparer means any individual described in Section 7701(a)(36) of the Internal Revenue Code and 26 C.F.R. 301.7701-15 .

  • Pre-Closing Tax Returns is defined in Section 6.7(b)(iii).

  • Additional Disclosure Notification The form of notification to be included with any Additional Form 10-D Disclosure, Additional Form 10-K Disclosure or Form 8-K Disclosure Information which is attached to this Agreement as Exhibit W.

  • 10-K Filing Deadline As defined in Section 11.05(a).

  • Pre-Closing Tax Return means any Tax Return that is required to be filed for any Acquired Companies, the Seller or any of its Affiliates with respect to a Pre-Closing Tax Period.

  • Section 336(e) Election has the meaning set forth in Section 7.06.

  • Distribution Statement has the meaning set forth in Section 5.02(c) of the Trust Agreement.

  • Allocation Statement has the meaning set forth in Section 2.5.

  • 10) Election has the meaning set forth in Section 6.05(a).

  • Information Statement means the information statement to be made available to the holders of Parent Shares in connection with the Distribution, as such information statement may be amended or supplemented from time to time prior to the Distribution.