definiens: means the final resolution of any Tax ( orother Tax matter ) for a taxable period that, under applicable law, is notsubject to further appeal, review or modification through proceedings orotherwise, including ( i ) by the expiration of a statute of limitations or aperiod for the filing of claims for refunds, amending Tax Returns, appealingfrom adverse determinations, or recovering any refund ( including by offset),(ii ) by a decision, judgment, decree, or other order by a court of competentjurisdiction, which has become final and unappealable, ( iii ) by a closingagreement or an accepted offer in compromise under Section 7121 or 7122 of theCode, or comparable agreements under laws of other jurisdictions, ( iv ) byexecution of an Internal Revenue Service Form 870 or 870AD, or by a comparableform under the laws of other jurisdictions ( excluding, however, with respect toa particular Tax Item for a particular taxable period any such form thatreserves ( whether by its terms or by operation of law ) the right of the taxpayerto file a claim for refund and/or the right of the Tax Authority to assert afurther deficiency with respect to such Tax Item for such period ), or ( v ) by anyallowance of a refund or credit, but only after the expiration of all periodsduring which such refund or credit may be recovered ( including by way ofoffset )