I have received a settlement offer from the IRS in a small tax case. This involves a discrete issue regarding whether income received by my client is taxable for self-employment tax purposes. The appeals officer agreed with me and so I was provided a proposed decision which states: “That there is no deficiency in income tax due from, nor overpayment due to, the petition for tax year 2015.” My client only hired me to defend against the assessment of self-employment tax but I think this income may not be taxable in whole or part as it was received as a settlement for a theft loss. I have advised the client to look at amending the return to potential get a refund. Does this agreement foreclose such a request?