The Department of Revenue treats settlement agreements entered into by the Commissioner of Revenue and taxpayers, except those governed by G.L. c. 62C, § 37A, as tax "return[s] or document[s] filed with the commissioner" under G.L. c. 62C, § 21(a). They are therefore confidential and may not be disclosed to third parties, except in accordance with G.L. c. 62C, § 21. However, as provided in G.L. c. 62C, § 37A(d), settlement agreements reached under the provisions of G.L. c. 62C, § 37A are "not ... subject to the confidentiality provisions" of G.L. c. 62C, § 21.

/s/Alan LeBovidge
Alan LeBovidge
Commissioner of Revenue

AL:LEM:lab

May 27, 2003

DD 03-5