A taxpayer who agrees with a revenue agent's proposed audit adjustment and signs Form 870 waives the right to pursue the appeals process within the IRS and the courts.

Question

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Signing Form 870 does not waive the taxpayer's right to file a claim for refund or to litigate the issue in court, but it does waive the restrictions on assessment and collection of the deficiency agreed upon.

A Taxpayer Who Agrees with a Revenue Agent's Proposed Audit