Extract to table

This agreement is final and conclusive as to the specific matters covered herein, and, except upon a showing of fraud, malfeasance, or misrepresentation of a material fact, the matters agreed to herein shall not be reopened or modified by either party

(EIN: 22-3741856), as reported on its Forms 1120 for the taxable years specified below, shall be increased by the following amounts

Payment shall be made by electronic funds transfer to the United States Treasury, referencing EIN 22-3741856 and the applicable taxable years

4 — Penalties The IRC § 6662(e) substantial valuation misstatement penalty in the amount of Fifteen Million Nine Hundred Seventy-Seven Thousand Dollars ($15,977,000) (approximately $15,980,000), as originally proposed by the Commissioner in the Notice of Proposed Adjustment dated October 12, 2023, is hereby fully abated and shall not be asserted or assessed against the taxpayer for any of the taxable years at issue

The taxpayer retains the right to seek relief from double taxation through the competent authority process, and the Commissioner agrees to cooperate in any such process in accordance with applicable law and treaty obligations

Nothing in this agreement shall be construed as an admission by either party regarding the correctness or incorrectness of any position taken during the examination or Appeals proceedings