In Crandall v. Commissioner (available here), in a win for taxpayers who have gone through the IRS’s offshore voluntary disclosure program (OVDP), the United States Tax Court held that the IRS was bound by the terms of a closing agreement and could not assert a deficiency (or penalty) greater than the amounts originally agreed to under the OVDP. Our good friends at Agostino & Associates, P.C., and K&F partner Lawrence (Larry) Sannicandro, represented the taxpayers.
