1. (a) The written notice of the final determination of federal estate tax due shall include copies of any final determination report, any compromise agreement, the closing letter, any court decisions, and any other available evidence of the final determination.

2. (b) A final federal determination is an irrevocable determination of a taxpayer's liability from which there exists no further right of appeal, either administrative or judicial. Some examples of final determination dates are:

   1. (1) A closing agreement under Section 7121 of the Internal Revenue Code finally and irrevocably adjusting and settling a tax liability.
   2. (2) A decision by the United States Tax Court or a judgment, decree or other order by any court of competent jurisdiction which has become final.
   3. (3) A final disposition of a claim for refund.
   4. (4) An assessment pursuant to a waiver filed under Section 6213 (d) of the Internal Revenue Code or pursuant to a comprise.

Note: Authority cited: Section 14103, Revenue and Taxation Code. Reference: Section 13504, Revenue and Taxation Code.

History

1. New section filed 4-29-96; operative 5-29-96 (Register 96, No. 18)