An installment agreement is a collection arrangement, not a determination that the tax is correct. Section 6159 supplies the statutory authority and several protections and procedures that apply while an agreement or qualifying request is pending or in effect.
What the authority does
The Secretary may enter a written agreement allowing payment in installments when doing so will facilitate full or partial collection. The statute addresses review, user fees, modification or termination, notice, appeals, and restrictions on levy during specified stages of the process.
Why it matters in a tax controversy
Before proposing a monthly payment, the account should be tested for filing compliance, current deposits, lien consequences, collection expiration dates, penalty accruals, default risk, and whether a hardship or partial-payment alternative is more appropriate. A payment that is merely affordable today can be strategically poor over the remaining collection period.
What it does not answer by itself
Approval does not erase penalties or interest, guarantee lien withdrawal, or prevent default if future obligations are missed. The statute also does not supply the financial calculation used for every agreement; regulations, Internal Revenue Manual criteria, and the particular account control much of the administration.
Research and case checkpoints
- Verify all required returns and current estimated-tax or payroll-deposit obligations.
- Calculate the remaining collection period for each assessment.
- Compare streamlined, full-pay, partial-payment, and hardship possibilities.
- Review the effect of a request, rejection, appeal, default, or termination on levy and limitations periods.
Primary and official sources
Currency note: Check the current text, amendment history, effective date, and the version governing the tax period or agency action before relying on this summary.