The closing agreement was not published by the agency and its reasoning has never been set out on the public record. Reporting in 1997 raised the question of how the reversal came about without settling it, and the agreement's own terms were reported rather than officially released.
What would resolve this Release of the agency's internal deliberative record, or a completed freedom of information action producing the file behind the decision rather than the agreement alone.
OpenTax law and administrative historyThe Seattle Times, Scientologists' Deal With IRS: $12.5 Million