Form 870-L - Agreement To Assessment And Collection Of Deficiencies In Tax For Partnership Adjustments, Additions To Tax, And Affected Items

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Department of the Treasury — Internal Revenue Service
IN REPLY
870-L
AGREEMENT TO ASSESSMENT AND COLLECTION
Form
REFER TO:
OF DEFICIENCIES IN TAX FOR PARTNERSHIP ADJUSTMENTS,
(Rev. 5-2006)
ADDITIONS TO TAX, AND AFFECTED ITEMS
Taxpayer(s) name(s), address and ZIP code:
Name of Partnership:
Tax Year(s) Ended:
Taxpayer Identifying Number:
Name of Tax Matters Partner:
Taxpayer Identifying Number:
PART I – OFFER OF AGREEMENT FOR PARTNERSHIP ITEMS
Under the provisions of section 6224(c) and 7121 of the Internal Revenue Code (IRC), the Commissioner
of Internal Revenue and the undersigned taxpayer(s) agree to the determination of partnership items of
the partnership for the years shown on the attached schedule of adjustments. The undersigned
taxpayer(s), in accordance with IRC sections 6224(b) and 6213(d), also waive(s) the restrictions provided
in IRC sections 6225(a) and 6213(a) and consent(s) to the assessment and collection of any deficiency
attributable to partnership items as determined in this agreement (with interest as required by law).
This agreement is conditional, and will not become effective or final until this agreement form is returned to
Internal Revenue and is signed for the Commissioner. The one year extension of the period of limitations
on assessment under IRC section 6229(f) will not begin to run until the date the Commissioner’s
representative signs this form for the Commissioner. If this is a partial agreement, the period of limitations
for assessing any tax attributable to the settled items shall be determined as if this agreement had not
been entered into.
If this agreement form is signed for the Commissioner, the treatment of partnership items under this
agreement will not be reopened in the absence of fraud, malfeasance, or misrepresentation of fact; and
no claim for an adjustment of partnership items, or for a refund or credit based on any change in the
treatment of partnership items may be filed or prosecuted.
Phone Number
Signature of Taxpayer
Date Signed
Signature of Taxpayer
Date Signed
Phone Number
By (Signature and Title)
Date Signed
Phone Number
Date accepted for Commissioner
Signature
FOR
INTERNAL
REVENUE
Office
Title
USE ONLY
870-L
(See Instructions for Signing Agreement)
Catalog Number 10428C
Form
(Rev. 5-2006)

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