Want closure with the California Franchise Tax Board? Consider obtaining a “Closing Agreement “ for tax treatment on an issue.
Nice article by Franchise Tax Board Chief Counsel on “Closing Agreements “
You may request a closing agreement at any time during the administrative process. If you are currently in the audit, protest, or appeal phase of the administrative process, you should make a request to the FTB professional that is currently working with you. When the request is made, the FTB professional will review the request to determine if a closing agreement is the proper instrument for your particular situation and notify you as to whether a closing agreement would be an appropriate tool in the current dispute.
The use of a closing agreement can be an effective tool in tax planning for future transactions that are similar. While the closing agreement only applies to a specific issue, taxpayer, and tax year the FTB should be consistent in entering these agreements.
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