---
kind: "section"
citation: "26 U.S.C. § 7121"
title: "26"
title_heading: "Internal Revenue Code"
number: "7121"
heading: "Closing agreements"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/7121"
units:
  - "Subtitle F — Procedure and Administration"
  - "Chapter 74 — Closing Agreements and Compromises"
---

# §7121. Closing agreements

- (a) **Authorization—** The [Secretary](/usc/26/7701.md?p=a-11-B) is authorized to enter into an agreement in writing with any [person](/usc/26/7701.md?p=a-1) relating to the liability of such [person](/usc/26/7701.md?p=a-1) (or of the [person](/usc/26/7701.md?p=a-1) or estate for whom he acts) in respect of any internal revenue tax for any taxable period.
- (b) **Finality—** If such agreement is approved by the [Secretary](/usc/26/7701.md?p=a-11-B) (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—
  - (1) the case shall not be reopened as to the matters agreed upon or the agreement modified by any officer, [employee](/usc/26/7701.md?p=a-20), or agent of the [United States](/usc/26/7701.md?p=a-9), and
  - (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.

## Source credit

(Aug. 16, 1954, ch. 736, 68A Stat. 849; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)

## Notes

### Editorial Notes

### Amendments

1976—Subsecs. (a), (b). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.