- 18 - As relevant herein, section 6159 authorizes the Commissioner to enter into an installment agreement with taxpayers to satisfy their tax liabilities if the Commissioner determines that such agreements will facilitate the collection of the liability.7 Sections 301.6159-1, 301.6320-1, and 301.6330-1, Proced. & Admin. Regs., together with the Internal Revenue Manual (IRM), provide the procedures for determining whether an installment agreement will facilitate collection of the liability. See, e.g., Orum v. Commissioner, supra at 13 (upholding Commissioner’s determination because the taxpayers failed to timely provide requested information regarding their current financial condition in accordance with IRM guidelines); see also 2 Administration, Internal Revenue Manual (CCH), pt. 5.19.1.5.4.1, (July 1, 2002). For an installment agreement to be approved, a taxpayer must be in compliance with all filing requirements. Internal Revenue Manual (CCH) pt. 5.14.1.4.1(5) (July 1, 2002); see Rodriguez v. Commissioner, T.C. Memo. 2003-153 (a determination that a taxpayer is not entitled to a collection alternative such as an offer-in-compromise does not constitute an abuse of discretion if the taxpayer was not currently in compliance with Federal tax laws). 7 Sec. 6159(c), an exception not herein presented, requires the Commissioner to enter into an installment agreement in certain circumstances (generally involving tax liabilities of less than $10,000).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