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“Partial Payment” means partial payment of the total amount due. Check out this part of the IRM 18.104.22.168 (04-26-2019)
All taxpayers are expected to immediately full pay delinquent tax liabilities. When this is not possible, taxpayers may be allowed to pay their liabilities over a prescribed period of time. If full payment cannot be achieved by the Collection Statute Expiration Date (CSED), and taxpayers have some ability to pay, the Service can enter into Partial Payment Installment Agreements (PPIAs). The American Jobs Creation Act of 2004 amended IRC §6159 to provide this authority.
The Collection Statute Expiration Date refers to the last date the IRS can collect on a debt – generally, ten years from the date of assessment. If you file a tax return, the date of assessment is the date the IRS processes the tax return and posts it to your account for that year. Thus, if the latest assessment date for the years covered by your installment agreement is sometime this year, the CSED should be in 2030 – ten years from now, not eleven.
A partial payment installment agreement cannot be approved by the IRS without an evaluation of your finances. Usually, this means you have to complete Form 433-A, the Collection Information Statement. (See IRM 22.214.171.124.1(1).)
credit: © DeFilippis Financial Group (Rev. 05/29/2012)
For most taxpayers, whether a business or individual, the chance of an IRS examination (audit) is about 1%. For a taxpayer earning over $1,000,000 per year, the odds exceed 8%. Less than 1% of S-corporations and partnerships filed are audited.
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