Form 870-L - Agreement To Assessment And Collection Of Deficiencies In Tax For Partnership Adjustments, Additions To Tax, And Affected Items Page 2

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PART II – OFFER OF AGREEMENT FOR AFFECTED ITEMS
Under the provisions of sections 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 partner level determinations (affected items). These items:
(1) limit the amount of partnership item deductions or credits at the partner level
pursuant to IRC sections 704(d), 465, 469, or any provision of the IRC as set
forth in the attached schedule of adjustments, and/or
(2) are additions to tax, and interest under section 6621(c) of the Internal Revenue
Code, as shown on the attached schedule of adjustments.
The undersigned taxpayer(s), pursuant to the provisions of IRC sections 6224(b) and
6213(d), further agree(s) to waive the restrictions provided by section 6213(a) of the
IRC and consent(s) to the assessment and collection of tax attributable to the
application of IRC sections 704(d), 465, 469, or any provisions of the IRC as set forth in
the schedule of adjustments, and any additions to tax, and interest under IRC section
6621(c), as set forth in the attached schedule of adjustments; plus any interest provided
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 by the Commissioner’s representative.
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 the specified
affected items under this agreement will not be reopened in the absence of fraud,
malfeasance, or misrepresentation of fact; and no claim for an adjustment to these
affected items or for a refund or credit based on any change in the treatment of these
affected items may be filed or prosecuted.
Signature of Taxpayer
Date Signed
Phone Number
Date Signed
Phone Number
Signature of Taxpayer
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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