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Part 5. Collecting Process

Chapter 14. Installment Agreements

Section 11. Defaulted Installment Agreements, Terminated Agreements and Appeals of: Proposed Terminations (Defaults), and Terminated Installment Agreements

5.14.11  Defaulted Installment Agreements, Terminated Agreements and Appeals of: Proposed Terminations (Defaults), and Terminated Installment Agreements

5.14.11.1  (09-26-2008)
Overview

  1. When taxpayers provide inaccurate information or do not meet the terms of their agreements, the agreements may be terminated. Taxpayers may appeal proposed terminations. This chapter provides procedures for default and termination of agreements for both IDRS and manually monitored agreements. Exhibit 5.14.11.1–1 is a table defining the status of agreements (New, Current, Defaulted, and Terminated) with permissible actions for each status.

5.14.11.2  (09-26-2008)
Reason for Termination of Installment Agreements Without Notice to Taxpayers

  1. The Internal Revenue Service may terminate installment agreements without advance notice if the Secretary (or his duly authorized representative, e.g. revenue officer or other contact employee) believes that collection of the tax covered by the installment agreement is in jeopardy.

    Caution:

    See IRM 5.14.1.5 regarding levy restrictions. Collection is considered to be in jeopardy (see IRM 5.14.1.5(2)) if one of the conditions allowing a jeopardy assessment exists. See Policy Statement P-4–88 and IRM 5.11.1.3.9 regarding Notices of Levy.

5.14.11.3  (09-26-2008)
Reasons for Proposing Termination (Defaulting) of Installment Agreements

  1. The Internal Revenue Service may propose termination of (place in default) installment agreements if taxpayers:(See IRM 5.14.11.3(2) for additional information relative to defaulting agreements for each of these reasons.)

    1. fail to pay an installment payment when due under the terms of an agreement;

    2. fail to pay another tax liability at the time such liability is due;

      Note:

      This includes other TINs for the same taxpayer. Examples would be a sole proprietor and an IMF or a partnership and an IMF.

    3. fail to provide a financial condition update upon request;

    4. provided information prior to the date such agreement was entered into that was inaccurate or incomplete; or,

    5. fail to pay a modified payment amount based upon updated financial information. (See IRM 5.14.4.1.1.)

  2. Use the following procedures (if applicable) for defaulting agreements for each of the above reasons.

    1. For IRM 5.14.11.3(1)(a) (fails to pay an installment payment when due under the terms of the agreement), non-receipt of the installment payment is grounds for proposing default. These defaults may be completed either systemically or manually (See IRM 5.14.11.4 and IRM 5.14.11.5). Defaults may be initiated by field, Centralized Case Processing, ACS or Campus personnel.

    2. For IRM 5.14.11.3(1)(b) (fails to pay another tax liability at the time such liability is due), non-receipt of a payment is grounds for proposing default. These defaults may be completed either systemically or manually (See IRM 5.14.11.4 and IRM 5.14.11.5). Defaults may be initiated by field, Centralized Case Processing, ACS or Campus personnel.

    3. For IRM 5.14.11.3(1)(c) (fails to provide a financial condition update upon request), non-receipt of requested information is grounds for proposing default. These defaults may be completed manually or systemically. Defaults may be initiated by field, Centralized Case Processing, ACS or Campus personnel.

    4. For IRM 5.14.11.3(1)(d) (provides information prior to the date such agreement was entered into that was inaccurate or incomplete), document case histories regarding the circumstances of the case. These defaults may be completed manually by field, Centralized Case Processing, ACS or Campus personnel.

    5. For IRM 5.14.11.3(1)(e) (fails to pay a modified payment amount based upon updated financial information), non-receipt of a payment is grounds for proposing default. These defaults may be completed manually only. Defaults may be initiated by field, Centralized Case Processing, ACS or Campus personnel.

  3. Installment agreements may not be defaulted nor terminated for reasons other than those listed in this section.

    Note:

    IDRS allows coexistence of delinquent return status and status 60 (i.e., an entity can have a TDI open on one module and status 60 on other modules). The TDI does not cause default of the status 60 balance due accounts.

5.14.11.4  (09-26-2008)
Defaults and Terminations: IDRS Monitored Agreements

  1. When a taxpayer does not meet the terms of an installment agreement, she or he will be notified in writing and given 30 days to comply with the terms of the agreement before the agreement is terminated. A taxpayer with an IDRS-monitored installment agreement will receive notice CP 523, Defaulted Installment Agreement — Notice of Intent to Levy. (See IRM 5.14.8.2.) The notice or letter is sent by certified mail for taxpayers with domestic addresses, or by registered mail if taxpayers have foreign addresses. Defaulted Installment Agreement notices must be provided for all defaulted agreements (except in jeopardy situations) including those proposed terminations because the taxpayer provided inaccurate or incomplete information prior to entering into the agreement. See IRM 5.14.1.5(2) for cases involving jeopardy situations.

  2. An account on which the taxpayer has received CP 523 or Letter 2975 (DO) is commonly referred to as a "defaulted agreement" , but the agreement will not be terminated until the expiration of the 30 day period beginning on the date the notice is issued.

  3. No levies may be issued on tax periods included in agreements for 90 days after mailing Notice 523 or Letter 2975 (DO). (See IRM 5.14.1.5 – Levy Restrictions and Installment Agreements.) Note that this 90 day period includes the following timeframes:

    1. thirty (30) days after a Notice 523 is mailed, proposing termination of an agreement. For IDRS monitored agreements, the Notice 523 is mailed when the account status changes to 64.

      Note:

      Allow an additional 15 days beyond this timeframe for taxpayers to mail appeals of defaulted agreements.

    2. For an additional 30 days after the date of the termination of the agreement.

      Note:

      Although the termination date of record for the agreement is 30 days from the date of the Notice 523, allow an additional 15 days beyond this second 30 day period for taxpayers to mail appeals of terminated agreements.)

  4. If there is no response from the taxpayer, the account status will change from status 64 to either status 22 or 26. This status change occurs thirteen (13) weeks (or cycles) after mailing Notice 523. The 13 cycle period allows for 90 days between the date of the notice and the change to balance due status.

  5. TC 971 AC 063 remains on tax modules for taxpayers in installment agreement status until 90 days have passed since Notice 523 is sent. The TC 971 AC 063 may not be reversed during this period of time. See IRM 5.14.1.5.

    Note:

    If the installment agreement also included a backup Form 53, "Report of Currently Not Collectible Taxes" , when the taxpayer defaults the installment agreement, the 530 code is input, the taxpayer receives Notice 523 and the TC 971 AC 163 automatically uploads.

  6. If installment agreements are not reinstated after they default and agreements are terminated, then, at the end of 13 cycles, Masterfile generates TC 971 AC 163 to reverse TC 971 AC 063. This process is triggered by the status change from 6X to any other status. The systemic upload of TC 971 AC 163 also provides for:

    1. change in failure to pay penalty rate, if previously reduced, to one-half (0.5) percent;

    2. removal of the installment agreement indicator; and

    3. allow systemic levies.

    Use TC 972 AC 063 only when TC 971 AC 063 was input in error.

    Note:

    Before 01–01–2000, TC 971 AC 163s were not generated by status changes.

  7. CP 523 directs taxpayers to reply to campuses.

5.14.11.5  (09-26-2008)
Default and Termination Procedures for IBTF Installment Agreements: Centralized Case Processing and Field Actions

  1. The procedures provided in IRM 5.14.11.5(2) through (10) below should be followed for accounts in default for failure to pay additional liabilities when due, or failure to make installment payments.

  2. The Centralized Case Processing employee should verify that CP 523 notice was sent by the Campus.

  3. If CP 523 notice was not sent, input command code IADFL. This will cause:

    1. the account to update to status 64; and

    2. issuance of the default notice CP 523.

    Note:

    See IRM 5.14.11.4, which explains the notice and actions that can be taken.

  4. If payment was received from the taxpayer, notate the case history and verify that the case was reinstated to status 60.

  5. If, after receipt of payment, the case was not reinstated to status 60, verify that there is no other reason for the default condition, then request reinstatement of status 60.

  6. If payment was not received, attempt to contact the taxpayer and request payment. If no payment is received within 45 days from the date of the CP 523, and the agreement has not been reinstated or a new agreement reached, the agreement will be automatically terminated on the 46th day:

    1. Letter 1058(DO) may be issued if it has not been issued previously. (See IRM 5.14.11.6 and IRM 5.11.1.2.2.2 regarding issuance of Letter 1058(DO).) or,

    2. if Letter 1058 has previously been issued and 180 days have passed, Letter 3174P should be used. (See IRM Exhibit 5.11.1–3.)

  7. If taxpayers do not respond within 90 days from issuance of notice CP 523, follow the procedures provided in IRM 5.14.11.6 (4).

    1. After input of the TC 971 AC 163, transfer the case to the appropriate group pursuant to zip code and grade level using the ICS parameter tables. (See IRM 5.14.11.5(7)(b).)

    2. If an Other Investigation (OI) is currently assigned to a field employee, transfer the case to that employee.

    3. Ensure that the case history is documented with the actions taken, including a record of responses received from taxpayers and third parties.

  8. If the taxpayer did respond to the default notice, follow the procedures in IRM 5.14.11.7, IRM 5.14.11.8, and IRM 5.14.11.9.

  9. If not resolved pursuant to the procedures listed in IRM 5.14.11.5(8), cases should be transferred to appropriate collection field groups pursuant to zip code and grade level using ICS parameter tables. If there is currently an OI assigned to Collection, transfer the case to that employee. (See IRM 5.14.7.5 regarding OIs and IRM 5.14.8.4 regarding monitoring.)

  10. If Appeals is conducting an investigation and or hearings on an unrelated issue, the case should be held in Centralized Case Processing until Appeals makes a determination. See IRM 5.14.11.5(16)(e) regarding appeals of installment agreement terminations.

    1. If assistance is needed from the collection field group before the case is transferred to the field, an OI may be sent to the collection field function to perform specific requests.

    2. If Appeals determines an installment agreement is not the proper case resolution, or if the resolution cannot be completed within Centralized Case Processing, forward the case to the appropriate collection field group pursuant to the zip code and grade level of the case listed in the parameter tables located in ICS. If there is currently an OI assigned to field Collection, transfer the case to the proper employee.

    3. Before transferring it to collection field function, the Centralized Case Processing employee should ensure that 30 days have passed since termination of the installment agreement and the case is ready to proceed with collection action. The employee should also ensure that all actions taken are documented in the case history and TC 971 AC 163 is input on appropriate modules.

  11. Before sending cases back to collection field function, the directions in IRM 5.14.11.5(10)(b) should be followed.

  12. The procedures provided in IRM 5.14.11.5(13) through (16) should be followed for agreements defaulted because taxpayers failed to make required federal tax deposits or failed to file returns at the time such returns were due, after contact by the centralized case processing employees.

  13. Verify deposits were required. This may be verified by

    1. taxpayer contact; or

    2. summons of bank records; or

    3. Other Investigation to the collection field function to verify.

  14. If the taxpayers file the required returns or make delinquent deposits, leave the agreement in status 60 and monitor as before.

  15. If it is verified that taxpayers are no longer required to file returns or make deposits, notate cases accordingly and continue monitoring.

  16. If taxpayers do not file required returns or make delinquent deposits, and it was verified that such returns or deposits were required, then:

    1. on the first day after the due date of the return, follow the 6020(b) procedures provided in IRM 5.1.11.9, including completion of Letter 1085 or 1616.

    2. mail Letter 1085 or 1616 along with Letter 2975 proposing termination of the installment agreement.

      Note:

      Termination based upon a proposed assessment may only be employed in the case of tax returns that may be prepared under IRC 6020(b).

    3. if the taxpayer has not responded after the 30 day period provided in Letter 1085 or 1616 (plus 15 days for mail time), check IDRS to ensure taxpayers have not filed the returns. If returns have not been filed, immediately process proposed returns in accordance with IRM 5.1.11.9.

      Note:

      Prompt assessment of returns should be considered if enforcement action is being considered and the liabilities for returns are to be included on levies.

    4. If the taxpayer has not made the required deposits, or fully paid the amount due on the return proposed (or assessed) under IRC 6020(b) after the default period (30 days from Letter 2975 plus 15 days for mailing), then the agreement is considered terminated.

      Note:

      Letter 1058 can be sent if not sent previously. See IRM 5.14.11.5(6).

    5. (See IRM 5.14.11.5(10) regarding Appeals involvement on cases where appeals are ongoing on other issues.) Taxpayers may appeal proposed terminations (defaults) of agreements. The appeal period is 30 days, plus 15 days for mail time from the date Letter 2975/CP 523 was sent. Taxpayers may appeal terminations of agreements. The appeal period is 30 days plus 15 days for mail time from the date of termination. (see IRM 5.14.11.5(11))

    6. Timely appeals must be resolved before levy action on balance due accounts included in terminated installment agreements. This requirement also applies to appeals that have been initiated, but not resolved (see IRM 5.14.1.5.)

5.14.11.6  (09-26-2008)
Defaults and Terminations: Manually Monitored Installment Agreements

  1. When an agreement defaults, taxpayers with IDRS-monitored agreements receive CP 523, Defaulted Installment Agreement — Notice of Intent to Levy. In the case of taxpayers with manually-monitored agreements, Letter 2975(DO) Notice of Defaulted Installment Agreement under IRC section 6159(b) — "Notice of Intent to Levy under IRC section 6331(d)" — will be issued when an agreement defaults. Like the CP 523, Letter 2975 (DO) gives the taxpayer 30 days to comply with the terms of the agreement before an installment agreement is terminated. Letter 2975(DO) must be issued no less than 30 days before the date of termination in all non-jeopardy situations.

  2. Issue Letter 2975(DO) as follows:

    1. complete the identification information at the top of the letter;

    2. provide the reason the agreement defaulted (see IRM 5.14.11.3);

    3. compute penalty and interest to 30 days from the date of the letter;

    4. include Publication 594, The IRS Collection Process, and a non-postage-paid return envelope with the letter;

    5. include Publication 1660, Collection Appeal Rights. (See IRM 5.14.9.4 — Collection Appeals Program); and

    6. deliver Letter 2975(DO) in any of the following ways: (1) give it to the taxpayer in person; (2) leave it at the dwelling or usual place of business of the taxpayer; (3) send it by certified or registered mail (return receipt requested).

      Note:

      If there is no response from the taxpayer, agreements are terminated 30 days after sending Letter 2975.

  3. See IRM 5.11.1.2.2.3 regarding the issuance of Letter 1058 after the 45 days from the issuance of Letter 2975, if the taxpayer does not appeal.

    1. As long as the taxpayer has not timely appealed the default or termination of their installment agreement and Letter 1058 was issued after 45 days from the issuance of Letter 2975(DO), Letter 1058 is considered valid and does not have to be rescinded.

  4. After 90 days have passed from the issuance of Letter 2975 and

    1. the installment agreement has not been reinstated;

    2. a new installment agreement has not been placed into effect and/or will not be entered into soon;

    3. the taxpayer has not requested a Collection Appeals Program hearing for the default or termination of the installment agreement; or

    4. the taxpayer has not requested a Collection Due Process hearing,

    then the contact employee should request input of TC 971 AC 163 on all appropriate periods. (See IRM 5.14.11.4(5)).

    Note:

    In addition to checking the case history, recent correspondence and other casefile documentation, check IDRS for TC 520 CC 76 or 77 to determine if there is an active CDP Appeal. (See IRM 5.1.9.3.6.1)

    Note:

    IDRS TC 971 AC 275 indicates that a CDP Appeal request (not yet opened as a case) has been received. IRM 5.11.7 – Automated Levy Programs – will provide further information after this programming request is implemented.

  5. No levies may be issued on tax periods included in agreements for 90 days after mailing Letter 2975(DO) to taxpayers. See IRM 5.14.11.4(2) and IRM 5.14.11.4(3) for timeframes.

  6. See IRM 5.14.1.5(2)(c) which allows levies on other periods not included in the installment agreement being defaulted or terminated.

5.14.11.7  (09-26-2008)
Considerations after Default or Termination, Including Reinstatement

  1. If a taxpayer visits a local office in response to a defaulted or terminated installment agreement notice, appropriate action should be taken based on the circumstances of the case. Before reinstating a defaulted or terminated agreement, consider:

    1. the taxpayer’s reason for default or termination.

    2. the taxpayer’s ability to pay (see IRM 5.14.9.2 for managerial approval requirements on defaulted or revised installment agreements);

    3. the statute expiration date (see IRM 5.14.2);

    4. updating levy sources, address, and telephone numbers;

    5. a payroll deduction agreement or Direct Debit Installment Agreement;

    6. the necessity of filing or refiling a Notice of Federal Tax Lien (NFTL) (See IRM 5.14.11.8 and IRM 5.14.1.4.2);

    7. if the taxpayer is in compliance with estimated tax requirements and/or has adequate withholding;

    8. if the taxpayer is in compliance with federal tax deposits; and,

    9. if the taxpayer is in compliance with filing of all required returns due.

  2. Defaulted or terminated agreements may be reinstated with no managerial approval, and no financial statement analysis only if:

    1. The agreement is in default or was terminated because of an additional liability and if addition of that new liability will result in no more than two additional monthly payments and the agreement will not extend beyond the CSED. A lien determination is required for these agreements.

    2. The agreement meets streamlined or IBTF Express criteria and the taxpayer has not defaulted an installment agreement in the 12 months prior to the current default. These agreements require no lien determination. (See IRM 5.14.5.2 and IRM 5.14.5.4 regarding Streamlined and IBTF Express criteria.)

  3. In all other cases, except those listed in IRM 5.14.11.7(2), financial statement analysis is required to re-evaluate the taxpayer’s ability to pay.

    1. Note:

      If agreements are in default (not yet terminated) they must be reinstated if taxpayers remedy the default (unless there is another reason for default). (See list of reasons for default/termination in IRM 5.14.11.3.)

  4. If the agreement is in default or was terminated solely due to missed payments under the terms of the agreement, whether or not the taxpayer was given a systemic skipped payment before receiving the CP 523, subsequent skipped payments may be permitted in emergency situations. Managerial approval is required. Do not allow skipped payments if the agreement will not fully pay the taxes before the CSED.

    Note:

    CSED waivers may only be secured with new partial payment installment agreements. Waivers secured with existing installment agreements will not be approved. (See IRM 5.14.2.2(4) and IRM 5.14.9.2(8).)

  5. If a taxpayer skips more than two payments in a twelve-month period, including the systemic skip, the agreement will be defaulted by CSCO unless the taxpayer provides a new or revised financial statement. Taxpayers need not appear in person for re-evaluation of their financial condition. Re-evaluation may take place by telephone, by FAX, or by other correspondence.

  6. If routine IDRS research shows that the taxpayer has moved out of the area, use the ICS transfer process to reassign the case to the appropriate location. If contact is made with taxpayers in these situations:

    1. attempt to secure the taxpayer’s telephone number, any new income and asset information and the taxpayer’s new address.

    2. If the taxpayer indicates that her/his financial condition is significantly different, note the file before transferring the case.

    3. Advise the taxpayer to contact the new office for financial review.

    4. If the installment agreement has less than twelve months remaining, it should not be transferred unless the taxpayer has requested transfer or the agreement is in default status.

  7. In the event an agreement or other IDRS action is required, except as noted in IRM 5.14.11.7(9), prepare Form 4844, Request for Terminal Action. The reason for the revision and managerial approval, as required by IRM 5.14.9.2, will be noted in the Remarks Section of Form 4844. Attach new Forms 433-D or 2159 and CIS to the form, if appropriate.

  8. If the taxpayer contacts the area office and the interview determines that a hardship exists, prepare Form 53 and file a Notice of Federal Tax lien, if appropriate. Secure necessary approval of Form 53 and forward the entire assembly, including a copy of the lien, to CSCO. Explain the required CSCO action in the Remarks Section of Form 4844.

  9. Correspondence responses received in the area office and requiring CSCO action on the installment agreement will be transmitted to CSCO.

5.14.11.8  (09-26-2008)
Lien Determinations: Defaulted/Terminated Installment Agreements

  1. Notice of Federal Tax Lien Filing on Periods Covered By Agreement:

    1. If, upon approval of an installment agreement the taxpayer was notified (either by checking a box on Form 433D or Form 2159, or it is indicated in the case history) that a Notice of Federal Tax Lien:

      • has already been filed;

      • will be filed immediately; or,

      • will be filed when tax is assessed,

      then no action is necessary beyond ensuring that the Notice of Federal Tax Lien was filed in the proper jurisdiction.

      Note:

      If the taxpayer moved to a new jurisdiction, a Notice of Federal Tax Lien may be filed in the new jurisdiction immediately, without regard to IRM 5.12.1.4.

    2. If, upon approval of an installment agreement, the taxpayer was notified (either by checking a box on Form 433D or Form 2159, or per the case history) that a Notice of Federal Tax Lien "may be filed if this agreement defaults" , then a federal tax lien may be filed immediately when the CP 523/Letter 2975 is mailed (or given to the taxpayer, or left at the taxpayer ’s last known address or place of business.)

    3. If no information regarding filing of the Notice of Federal Tax Lien was provided in the case history, nor on Form 433D or Form 2159 (no box was checked):

      • If it is determined the government’s interest is at risk, a lien may be filed when the CP 523/Letter 2975 is mailed, (given to the taxpayer, or left at the taxpayer’s last known address or place of business. (See IRM 5.12.1.2.16 for at risk situations.)

      • If collection is in jeopardy, then the lien may be filed. (See IRM 5.1.4 Jeopardy, Termination, Quick and Prompt Assessments.)

      • If collection is not in jeopardy or the government’s interest is not at risk, the Notice of Federal Tax Lien should not normally be filed for 90 days after the date CP 523/Letter 2975(DO) is issued.

  2. Notice of Federal Tax Lien Filing on Newly Assessed Periods:

    If a new liability is assessed after approval of an installment agreement, a lien determination should be made on the additional balance due tax period(s). (See IRM 5.12.2.8.1.)

  3. Documentation:

    When filing a Notice of Federal Tax Lien on taxpayers with defaulted or terminated installment agreements, document case histories regarding the lien determination. (See IRM 5.12.2.8.1.)

  4. Case Closure:

    If a Notice of Federal Tax Lien was filed on a period and the 45 days have not passed and the installment agreement is granted:

    1. retain sufficient documentation to respond to a Collection Due Process (CDP) appeal, if later filed; or, if in the judgment of the revenue officer a CDP appeal is likely the case may be kept open until 45 days have passed. (See IRM 5.14.1.4.2.)

    2. if it was determined the case should remain open and 30 days pass after filing Notice of Federal Tax Lien and the taxpayer or power of attorney verifies no request was made, close the case without waiting the additional 15 days.

    3. if the taxpayer does appeal the Notice of Federal Tax Lien, procedures in IRM 5.1.9.3 must be followed.

    Note:

    See IRM 5.14.1.4.2 regarding Notice of Federal Tax Lien and installment agreements.

5.14.11.9  (09-26-2008)
Appeals of Defaulted and Terminated Agreements

  1. Taxpayers may request a CAP hearing with Appeals for both:

    • proposed terminations (also known as "defaults" ) of installment agreements and

    • actual terminations of installment agreements.

    The right to this type of appeal is provided in Notice 523 and Letter 2975(DO). Taxpayers who request an appeal will follow the instructions in IRM 5.1.9.4.1, "Request for a CAP Appeal." No levy action may be taken on the periods included in the agreement, during the time period when taxpayers may appeal defaulted and terminated agreements. See IRM 5.1.9.4 and IRM 5.14.1.4(2) and IRM 5.14.9.4 on the "Collection Appeals Program."

  2. The right to appeal a termination of an installment agreement is provided by law. Therefore, the taxpayer has 30 days from:

    1. the date of proposed termination (default) of the installment agreement (Letter 2975(DO)/CP 523) to submit Form 9423, "Collection Appeal Request," if a CAP is requested for a proposed termination (default); and additionally

    2. the termination of the installment agreement, to submit Form 9423, "Collection Appeal Request," if a CAP is requested for a termination of an installment agreement.

    Also, 15 days is allowed for mailing time.

  3. Taxpayers need to be advised of the requirements and timeframes for requesting CAP hearings for defaults or terminations.

Exhibit 5.14.11-1  (09-26-2008)
Status of Agreements and Possible Actions

Status Of Agreements And Possible Actions (Exhibit 11-1)
NEW (No prior IA; or 46 days after termination and no response or after Appeals decision. Minimum 91 days after default Letter 2975/523 and beyond with no appeal. After input of TC 971 AC 163. $105 user fee) CURRENT (Agreement in status 60 after approval. TC 971 AC 063 input) DEFAULTED (Up to 46 days from issuance of Letter 2975/523 , if no appeal. Has TC 971 AC 063 but no TC 971 AC 163 reversal) TERMINATED (46 to 90 days after default Letter 2975/523, if no appeal. Has TC 971 AC 063 but no TC 971 AC 163 reversal. Note: 91 days after 2975/523 with no appeal, reinstatement is considered "New IA)"
CAN: NEW CURRENT DEFAULTED TERMINATED
EXTEND CSED ON ASSESSMENTS IN AGREEMENT (IRM 5.14.2.2) YES (Only with a partial payment installment agreement) NO YES (Only with a "new" partial payment installment agreement) YES (Only with a "new" partial payment installment agreement)
EXTEND CSED ON ADDITIONAL PERIODS NOT IN THE AGREEMENT YES (Only with a "new" partial payment installment agreement) YES (Only with a "new" partial payment installment agreement) YES (Only with a "new" partial payment installment agreement) YES (Only with a "new" partial payment installment agreement)
FILE OR REFILE NFTL (IRM 5.12.1; 5.14.1.5.2 and 5.14.11.7) YES YES (Unless we informed the taxpayer that a lien would not be filed and collection is not in jeopardy or at risk.) YES (Unless we informed the taxpayer that a lien would not be filed and collection is not in jeopardy or at risk.) YES (Unless we informed the taxpayer that a lien would not be filed and collection is not in jeopardy or at risk.)
REVISE OR MODIFY (NAME, SOURCE OF PAYMENT, DATE OF PAYMENT, AMOUNT OF PAYMENT) NA YES YES (considered to be a reinstatement) $45 user fee YES (considered to be a reinstatement) $45 user fee
ADJUST PAYMENT AMOUNT (AGREEMENT SPECIFIES INCREASE OR DECREASE ON CERTAIN DATE; FINANCIAL UPDATE) NA YES YES (Payment amount may be adjusted on defaulted agreements when they are reinstated.) NA
REINSTATE (CASE IN STATUS 6X) NA NA YES ($45 user fee) YES ($45 user fee)
REQUIRE MANAGER APPROVAL (SAME MANAGER MUST SIGN FORM 900(s) AND APPROVE AGREEMENT(S) ON THE SAME DATE CSED EXTENSION IS OBTAINED) YES (No, if agreement is Guaranteed, Streamlined, or IBTF Express NO (Yes, if a module is added that needs a CSED extension - note that this forms a "new" partial paymentagreement.) YES (No, if no default in the last 12 months and agreement is Guaranteed, Streamlined, or IBTF Express.) YES (No, if no default in the last 12 months and agreement is Guaranteed, Streamlined, or IBTF Express.)
REQUIRE FINANCIAL FORM YES (No, if agreement is Guaranteed, Streamlined, or IBTF Express.) NO (Yes, if financial review is required.) YES (No, if no default in the last 12 months and agreement is Guaranteed, Streamlined, or IBTF Express.) YES (No, if no default in the last 12 months and agreement is Guaranteed, Streamlined, or IBTF Express.)

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