---
title: "Prepare the facts schedule for a closing agreement"
url: "https://ailawframework.com/practice/taxation/prepare-the-settlement-deed-for-a-tax-dispute/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-X20261018-5-US"
practice_area: "Taxation"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Prepare the facts schedule for a closing agreement

> Build a table of the taxable periods, the tax, and the points in dispute from the file. Write no sentence of the closing agreement.

Canonical page: https://ailawframework.com/practice/taxation/prepare-the-settlement-deed-for-a-tax-dispute/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Taxation](https://ailawframework.com/practice/taxation.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| 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 | United States |
| Applies to | [Prepare the settlement deed for a tax dispute](https://ailawframework.com/practice/taxation/prepare-the-settlement-deed-for-a-tax-dispute.md) |

## Checking plan

- What the AI does: Build a table of the taxable periods, the tax, and the points in dispute from the file. Write no sentence of the closing agreement.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The agreement is final once approved, apart from the fraud, malfeasance and misrepresentation exception. The lawyer writes every sentence of it.
- Read the rest of § 7121(b) on a later suit before the agreement is signed.

## Sources

- [26 U.S.C. § 7121 (closing agreements)](https://www.law.cornell.edu/uscode/text/26/7121) (checked 2026-10-22)
- [IRS Office of Professional Responsibility, Issue 2026-19, Introductory Guidelines for Responsible AI Use in Federal Tax Practice](https://www.irs.gov/pub/opr-taxpros/issue-number-2026-19-introductory-guidelines-for-responsible-ai-use-in-federal-tax-practice.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*