It is not the part of the order tax professionals should be studying. Processing ContentBuried in the same order is a narrower, more consequential change: the tax audit immunity language from the original settlement got rewritten. A settlement agreement, a closing agreement under Section 7121, an IRS Appeals resolution or a Department of Justice Tax Division agreement all have defined boundaries. Review every engagement letter, settlement agreement and closing agreement you have drafted or advised on for audit protection language. Vague or general protection language will be construed narrowly against the taxpayer whenever the government has an incentive to revisit it.