Interesting IRM--SFR

[hughthehand]

[jwbbx]

I don't understand what the issue is here?

Form 870 is a waiver of restrictions on assessment. It is also used to accept over-assessments. The intended effect of Form 870 is to allow the taxpayer to pay the deficiency, stop the running of interest, and give up the right to go to Tax Court. The language of Form 870 permits reopening of issues, by either the taxpayer or the IRS. Form 870 is intended to be an informal settlement and is rarely reversed.

[hughthehand]

Most SFR's are not signed under penalties of perjury.