IRS Installment Agreements: A Treatise for Attorneys, CPAs, Accountants & Tax Preparers offers tax professionals a scholarly treatise on the IRS program that relieves taxpayers from the onslaught of the IRS collection apparatus. Installment agreements are offered to taxpayers who want to avoid IRS collections and repay back-taxes over time. This book offers a deep dive into the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures that comprise the IRS’ Installment Agreement program.
This is a resource book for tax professionals. Congress authorized relief from the IRS collections apparatus, including protection from bank levies, wage garnishments, lawsuits, and federal tax liens. “Routine” installment agreements are explored first, followed by the following: “Guaranteed” installment agreements; “Streamlined” installment agreements; “In-Business” installment agreements; and “Partial Payment” installment agreements. These five types of installment agreements are analyzed with relevant citations to the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures.
A separate discussion is presented for requesting an agreement, including a line-by-line analysis of IRS Form 9465, Installment Agreement Request. A 7-page Table of Contents, a 15-page Table of Authorities, and an 8-page Index aids a tax professional’s scholarly understanding. IRS Installment Agreements: A Treatise for Attorneys, CPAs, Accountants & Tax Preparers also explores what constitutes a “pending” installment agreement request, and the taxpayer’s power to withdraw a pending request. Key metrics are discussed regarding the IRS acceptance and rejection determinations. A taxpayer’s appellate rights to review rejected installment agreement requests is analyzed with specific references to the U.S. Tax Code and the Internal Revenue Manual. Next, this book analyzes the criteria for modifying approved installment agreements by taxpayers and the IRS. Installment payment amounts and methods are considered, including a taxpayer’s ability to liquidate or borrow against assets and the One-Year Rule to modify or eliminate expenses.IRS Installment Agreements: A Treatise for Attorneys, CPAs, Accountants & Tax Preparers also explores the IRS collection process with a discussion of IRS levies, tax liens, installment agreements, the offer in compromise program, and currently not collectible status.
Finally, powers of attorney and third-party authorizations are examined, including a line-by-line analysis of IRS Form 2848, Power of Attorney and IRS Form 8821, Tax Information Authorization.