New Jersey Administrative Code
Title 18 - TREASURY - TAXATION
Chapter 33 - CLOSING AGREEMENTS AND COMPROMISES
Subchapter 1 - CLOSING AGREEMENTS
Section 18:33-1.3 - Finality; determination of fraud
Universal Citation: NJ Admin Code 18:33-1.3
Current through Register Vol. 56, No. 18, September 16, 2024
(a)A fully executed closing agreement is final and conclusive for the period stated in the agreement, unless the Division discovers fraud, malfeasance, or misrepresentation of a material fact by the taxpayer.
1. The case shall not be
reopened as to the matters agreed upon or the agreement modified by an officer,
employee, or agent of the State of New Jersey; and
2. In any suit, action, or proceeding, such
agreement, or any determination, assessment, collection, payment, abatement, refund,
or credit made in accordance therewith, shall not be annulled, modified, set aside,
or disregarded. However, a closing agreement with respect to a tax period ending
subsequent to the date of the agreement is subject to any change in, or modification
of, the law enacted subsequent to the date of the agreement if the change or
modification is applicable to that tax period.
(b) Execution and approval of a closing agreement does not preclude an additional inspection of a taxpayers records to determine whether fraud, malfeasance, or misrepresentation of material fact exists as to execution of the agreement.
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