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          Secretary was authorized to enter into installment agreements               
          with any taxpayer “to satisfy liability for payment of any tax in           
          installment payments if the Secretary determines that such                  
          agreement will facilitate collection of such liability.”  The               
          applicable regulations contemplated that an installment agreement           
          would require the taxpayer to make scheduled periodic payments              
          until the tax liability is fully paid.9  Sec. 301.6159-1(a),                
          Proced. & Admin. Regs.  Respondent generally has the discretion             






               9 In the American Jobs Creation Act of 2004 (AJCA 2004),               
          Pub. L. 108-357, sec. 843(a)(1), 118 Stat. 1418, 1600, Congress             
          amended sec. 6159 to authorize the Secretary to enter into                  
          installment agreements “under which such taxpayer is allowed to             
          make payment on any tax in installment payments if the Secretary            
          determines that such agreement will facilitate full or partial              
          collection of such liability.”  The amendment is effective for              
          installment agreements entered into on or after Oct. 22, 2004.              
          AJCA 2004 sec. 843(c).  The legislative history describes the               
          reason for this amendment as follows:                                       
               The Committee believes that clarifying that the IRS is                 
               authorized to enter into installment agreements with                   
               taxpayers that do not provide for full payment of the                  
               taxpayer’s liability over the life of the agreement                    
               will improve effective tax administration.                             
                    The Committee recognizes that some taxpayers are                  
               unable or unwilling to enter into a realistic offer-in-                
               compromise.  The Committee believes that these                         
               taxpayers should be encouraged to make partial payments                
               toward resolving their tax liability, and that                         
               providing for partial payment installment agreements                   
               will help facilitate this. [H. Rept. 108-548, at 307                   
               (2004).]                                                               




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