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Payment Plans: Partial Pay Installment Agreements

April 23, 2026October 6, 2013 by Brotman Law

Introduction to Partial Payment Plans

The IRS expects that taxpayer will pay any back taxes that are owed in full at the time that they are due or will get on a payment plan for the amount in question. However, the IRS does not like to wait long for funds and payment plans are generally granted only in circumstances where the taxpayer can set up a payment plan to pay the balance owed, plus applicable penalties and interest within five years or prior to the expiration of the Collection Statute Expiration Date (CSED), whichever is first. However, there are some instances where this is not possible and the IRS is forced to consider the alternative. In these instances, the IRS will sometimes consider a partial payment plan for the taxpayer.

Key Takeaways

The IRS expects that taxpayer will pay any back taxes that are owed in full at the time that they are due or will get on a payment plan for the amount in question.
Partial payment plans and the IRS’s authority to consider them is a fairly recent development. The IRS was not previously able to consider partial payment plans and instead would just resort to adverse collection measures.
All that considered, partial payment plans are difficult to come by based on the fact that the IRS is essentially giving up on collecting the full balance owed.

IRS Payment Plan Requests – Form 9465-FS

April 23, 2026October 5, 2013 by Brotman Law

Introduction to IRS Payment Plans and Form 9465-FS

There are numerous options available to a taxpayer trying to resolve a balance due with the IRS.[1] One of the more prevalent options is to work out an IRS payment plan to pay down the liability in installment payments. When a taxpayer sets up a payment plan, they agree to make a specified monthly payment over a set period of time based on their ability to pay (as calculated by the IRS). In exchange for the taxpayer entering into their IRS payment plan, the IRS agrees to hold off on any adverse collection activity, including wage garnishments or bank levies, for the life of the installment agreement. Taxpayers can make a request for a IRS payment plan by filing IRS Form 9465-FS with the IRS.

Key Takeaways

There are numerous options available to a taxpayer trying to resolve a balance due with the IRS.
Form 9465-FS is only appropriate in certain circumstances and I have some practical advice for you in filing out the form that will maximize success in obtaining a successful IRS payment plan.
Second, it is a good idea to have an idea of what an acceptable IRS payment plan proposal is for your own planning purposes.

IRS Interest Abatements

April 23, 2026October 4, 2013 by Brotman Law

Introduction to IRS Interest Abatements

Any balance due that is owed to the IRS government will continue accrue interest on the amount of the outstanding tax obligation. The interest rate is generally pretty low in comparison with other types of debt,[1] but over time the amount of interest can add up and turn a small liability into a sizeable one. Unfortunately there is not too much to be done about your liability accruing interest and it is simply the cost of doing business with the IRS. However, there are certain mitigating circumstances where a taxpayer is able to do an IRS interest abatement in order to avoid the accrual of interest on some or all of the liability. When an IRS interest abatement occurs then the interest on a balance due can be abated altogether or just specific periods of time can be excluded from the interest calculation.

Key Takeaways

Any balance due that is owed to the IRS government will continue accrue interest on the amount of the outstanding tax obligation.
Please understand that an IRS interest abatement is a fairly difficult thing to accomplish and that its requirements are often rigid and inflexible.
Usually, the majority of these factors are not going to apply to the majority of taxpayer situations.

IRS Currently Non-Collectible Status

April 23, 2026October 3, 2013 by Brotman Law

Introduction to IRS Currently Non-Collectible Status

There are many ways to resolve a tax liability. You can set up a payment plan[1], attempt to settle a tax debt with an offer in compromise, or pay the balance that you owe in full. However, there are some instances where any amount of money would create an unfair economic hardship on the taxpayer. As a result, the IRS created a temporary hardship status known as IRS currently non-collectible status. This may be also referred to by the IRS or by tax practitioners as “CNC status” or 53ing an account (the code the IRS enters into the account to place it in it IRS currently non-collectible status. By placing an account in IRS currently non-collectible status, the IRS essentially halts all attempts at collection activity on an account until it feels that the taxpayer is ready to make payments again. IRS currently non-collectible status generally lasts anywhere from six months to over two years.

Key Takeaways

In order for the IRS to deem that a taxpayer account is non-collectible, the taxpayer must demonstrate a severe and apparent economic hardship.
In conclusion, IRS currently non-collectible status is not for everyone. However, if you do qualify, it can provide much needed temporary relief for your IRS collection issues.

Streamlined IRS Payment Plans

April 23, 2026October 3, 2013 by Brotman Law

Introduction to Streamlined IRS Payment Plans

One of the ways that you can resolve a liability is with an IRS payment plan. The IRS generally accepts payment plans when the taxpayer does not have sufficient assets available to pay their liability in full. Payment plans are seen as a method of compromise by the Service that the taxpayer to avoid any adverse collection activity (assuming they remain true to the conditions of the payment plan) while paying down their liability to the government. However, IRS payment plans can be difficult to negotiate, in part because the IRS usually requires a complicated financial statement on the part of the taxpayer. A little known trick to taxpayers though is that you are sometimes able to set up a payment plan and it is virtually guaranteed to be accepted without having to undergo much of the financial disclosures generally required by the IRS. These are known as streamlined IRS installment agreements or streamlined IRS payment plans.

Key Takeaways

One of the ways that you can resolve a liability is with an IRS payment plan. The IRS generally accepts payment plans when the taxpayer does not have sufficient assets available to pay their liability in full.
There are a few basic requirements to qualify for this type of tax relief. First, as is a requirement with any of the IRS payment plans, the taxpayer must be current on all tax filings and be up to date on all estimated tax payments over the course of the year.
In closing, if you meet the requirements for one of the streamlined IRS payment plans then they are a great way to alleviate your balance due without too much effort expended.

IRS Revenue Officers and Strategies for Dealing with Them – Part Five

April 23, 2026October 2, 2013 by Brotman Law

IRS Revenue Officers Tip # 6 – Knowing When to Get Tough

This is one of the most difficult things for me to advise you on how to do properly and effectively. Experience and knowledge of tax procedure have seasoned me throughout the years on when is an appropriate time to get tough with your revenue officer. The fact of the matter is that some revenue officers will try to take advantage of your weakened position and, if you let them, they will walk all over you. Some will go on a fishing expedition by requesting a ridiculous amount of documentation to substantiate the positions on your financial statement or for them to conduct their investigation. Some will take a hard line position by insisting on good faith payment amounts or monthly installment payment amounts that are too difficult for the taxpayer to meet without them suffering financial hardship.

Key Takeaways

This is one of the most difficult things for me to advise you on how to do properly and effectively. Experience and knowledge of tax procedure have seasoned me throughout the years on when is an appropriate time to get tough with your revenue officer.
As I mentioned, it is always better to be nice to the revenue officer and maintain an amicable relationship. However, sometimes this is not always possible and some people just need to be put into check.
In closing, I hope that these tips have been helpful for you in learning how I deal with revenue officers. My goal here was to assist you in achieving better results and to minimize the stress that an IRS collection matter can put on your life.

IRS Revenue Officers and Strategies for Dealing with Them – Part Four

April 23, 2026October 2, 2013 by Brotman Law

IRS Revenue Officers Tip #5 – Manage Your Expectations

One of my favorite IRS revenue officer sayings is that “the IRS is not a bank.” I find this slightly humorous in light of how many people have outstanding tax liabilities, but it also is a key takeaway about the mindset in which revenue officers approach their cases. IRS revenue officers are tasked with achieving the best possible resolution for the government, which means having the taxpayer satisfy their liability as soon as possible and/or squeezing as much money out of the taxpayer over the long run as they can without putting the taxpayer in financial hardship. Do not think for a second that they are going to sway from this purpose. In addition, revenue officers have a manager look over and approve all resolutions before they become final. If they slack in their job, they will hear about it from their managers.

Key Takeaways

One of my favorite IRS revenue officer sayings is that “the IRS is not a bank.
For example, one of the most important and difficult questions that I get from families with IRS problems is whether or not they are going to be able to keep their kids in their private schools or pay their college tuition on an IRS payment plan.
The main thing that I want to communicate to you is that you need to manage your expectations going into the process of what the end result is going to be.

IRS Revenue Officers and Strategies for Dealing with Them – Part Three

April 23, 2026October 2, 2013 by Brotman Law

IRS Revenue Officers Tip #3 – Get on the Revenue Officer’s Good Side by Making Life Easy For Them

Whatever your occupation, there are just some people that we encounter over the course of our chosen professions that make life difficult for us. They may turn in things that are substandard and require a lot of your time to make right. They may require constant follow up in order to get the things that you have asked for or miss appointments or deadlines without notifying you in advance. You may be one of these people to someone else, but absolutely do not be that person to your revenue officer. Getting on the revenue officer’s bad side is never a good thing. They will be generally less inclined to give you the resolution you are seeking and will make interactions with them more stressful and more difficult for you.

Key Takeaways

Whatever your occupation, there are just some people that we encounter over the course of our chosen professions that make life difficult for us. They may turn in things that are substandard and require a lot of your time to make right.
In addition, missing deadlines with the revenue officer can lead to harsh consequences. They can place a lien or levy you pretty quickly if you start to get out of line.
IRS revenue officers generally have a lot going on. They have roughly forty cases or so to sift through.

IRS Revenue Officers and Strategies for Dealing with Them – Part Two

April 23, 2026October 2, 2013 by Brotman Law

IRS Revenue Officers Tip #1 – Be Aggressive in Getting Everything Ready BEFORE the Revenue Officer Gets Involved.

Key Takeaways

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Tax resolution services for individuals and families (individual tax resolution- W2 and wage earners)
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There are two things that an IRS revenue officer judges themselves on when it comes to their own job performance: how much money they can collect toward the satisfaction of the liability and how fast they can close a case out. From the taxpayer standpoint, the most important objective other than a successful resolution to your account is to get them out of your life as soon as possible. No one likes the IRS looking over their shoulder and the longer that they linger than the more opportunity exists for them to make your life miserable. So do not let them.

IRS Revenue Officers and Strategies for Dealing with Them – Part One

April 23, 2026October 2, 2013 by Brotman Law

Introduction: About IRS Revenue Officers

IRS revenue officers are the most senior collections agents in the IRS.[1] IRS revenue officers handle those delinquent accounts that the IRS places the highest priority on, so much so that the government has assigned a local agent to specifically work the case in order to collect what is owed to the IRS. Generally, these individuals are highly trained and will incorporate an arsenal of tools and tactics in order to resolve the account in the favor of the IRS. They can retrieve third party records through summons, contact your employer, show up at your home or work, and seize a variety of assets (wages, accounts receivable, bank accounts, brokerage accounts, merchant accounts, etc…) in order to satisfy your tax liability. Having a revenue officer assigned to your collection account is a serious matter and it is important to take that person and their collection efforts seriously. Failure to do so may end you up on the bad side of the revenue officer and may make your life extremely difficult.

Key Takeaways

IRS revenue officers are the most senior collections agents in the IRS.
Many revenue officers are nice people and there some I would consider professional friends. However, I am under no illusions when I have to deal with a revenue officer.