- 16 - to accept or reject an installment agreement proposed by a taxpayer.10 Sec. 301.6159-1(b)(1)(i), Proced. & Admin. Regs. Eligibility for an installment agreement is based on the taxpayer’s current financial condition. Internal Revenue Manual (I.R.M.) sec. 5.14.1.4(1) (effective July 1, 2002). In requesting an installment agreement, a taxpayer must provide specific information, including a proposed monthly payment or other periodic payment amount. I.R.M. sec. 5.14.1.3(4) (effective July 1, 2002). The amount of the taxpayer’s payment depends on his or her ability to pay. I.R.M. sec. 5.14.1.4.3(1) (effective July 1, 2002). For an installment agreement to be approved, a taxpayer must be in compliance with all filing requirements. I.R.M. sec. 5.14.1.4.1(5) (effective July 1, 2002). At the time of the administrative process in this case, the Internal Revenue Service generally limited the length of installment agreements to the 10-year statutory collection period as provided in section 6502(a)(2)(A), “except in instances when a reasonable extension of the statutory period for collection will allow an agreement to be accepted.” I.R.M. sec. 5.14.2.1(2) (effective Mar. 30, 2002). Extensions were limited to no more 10 As an exception to this general rule, sec. 6159 requires the Commissioner to enter into installment agreements in certain circumstances (generally involving tax liabilities of less than $10,000) not presented by the instant case. See sec. 6159(c).Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011