Prepare the facts schedule for a closing agreement
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- Build a table of the taxable periods, the tax, and the points in dispute from the file. Write no sentence of the closing agreement.
- What the lawyer must review
- 26 U.S.C. § 7121 authorizes the Secretary to enter a written agreement with a person on that person's internal-revenue-tax liability for a taxable period. If the Secretary approves the agreement within the time it states, or a later time that is agreed, the agreement is final and conclusive and, except upon a showing of fraud or malfeasance or misrepresentation of a material fact, the case shall not be reopened as to the matters agreed upon, or the agreement modified, by any officer, employee or agent of the United States. You write the agreement. You read the rest of the section, including what it says about a later suit, before anything is signed. Office of Professional Responsibility Issue 2026-19: verify facts, citations and calculations before submission to the IRS.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Supporting preparation only. Consider narrowly defined preparation support after confirming the tool’s capability and permitted scope. The tool writes nothing into the document. Substantive advice, judgement and any restricted content remain with the responsible human. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Open each relied-on authority independently. Confirm its existence, current status, proposition and any quotation or pinpoint reference.
- Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
- Review operative clauses in the complete document, including definitions, cross-references, schedules and inconsistencies with the instructions.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.