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8.2.3.11
(10-23-2007)
Modification of Agreement in Related Cases
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In related cases the taxpayers may want an overassessment to offset a deficiency. This is accomplished by adding a paragraph
to the agreement form that reads similar to the following:
The undersigned taxpayer also consents and agrees to the application of that part of the overassessment that represents an
overpayment, and interest allowable thereon, as a credit to the deficiency, in tax of $ , and interest thereon, due from (related
taxpayer) for the year ; provided the amount of any overpayment and interest allowable thereon that is in excess of the deficiency
and interest is otherwise credited or refunded in accordance with section 6402 of the Internal Revenue Code, or corresponding
provisions of prior laws.
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Also make appropriate notation in Remarks section of Form 5402, Appeals Transmittal and Case Memo and Form 5403, Appeals
Closing Record.
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