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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).
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