Installment Agreements When Client Has Ability To Pay

I have seen this issue come up a couple of times now where the client wants to enter into an installment agreement but has the ability to pay. Working with Revenue Officers, the Revenue Officers are requesting full payment on the taxes due.


For streamlined installment agreements, practitioners should point out IRM 5.14.5.2(12), which states, "Taxpayer may be granted streamlined agreements based on the criteria provided in IRM 5.14.5.2.(1)-(11), even if they are able to fully pay their accounts."


For guaranteed installment agreements, practitioners should point out IRM 5.14.5.3(2), which states, "As a matter of policy, the Service grants guaranteed agreements even if taxpayers are able to fully pay their accounts."


So, there is no basis for Revenue Officers saying the IRS will not accept a streamlined or guaranteed installment agreement if the taxpayers have the full ability to pay.


Relevant Citations: IRM 5.14.5