- Instructor: Attorney Bob Schaller
- Lectures: 3
- Quizzes: 1
Appellate Review.
The Tax Code requires the IRS to conduct an “independent administrative review” before the rejection of an installment agreement is communicated to the taxpayer. 26 U.S.C. § 7122(e). Although the intention to recommend rejection should be relayed to the taxpayer, actual rejection of a proposed agreement must not be conveyed to a taxpayer prior to independent administrative review, and enforcement action may not be taken while installment agreements are pending. IRM § 5.14.1.4(11) (09-19-2014). No levy may be issued until after 45 days have passed since the IRS communicates to the taxpayer that installment agreement request was rejected. IRM § 5.14.9.7(13)(d) (12-18-2017); but see 26 U.S.C. § 6331(k) (30 days after rejection).
Overview
Independent Administrative Review
Appealing Rejection of Installment Agreement Request
Quiz
Reviews
Tax Law
This course teaches tax professionals that the Tax Code requires the IRS to conduct an “independent administrative review” before the rejection of an installment agreement is communicated to the taxpayer. Although the intention to recommend rejection should be relayed to the taxpayer, actual rejection of a proposed agreement must not be conveyed to a taxpayer prior to independent administrative review, and enforcement action may not be taken while installment agreements are pending.
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