4.20.1. Examination Collectibility Procedures

(1) This IRM provides guidelines and procedures for the collectibility program for SB/SE examiners. Examiners must strive for quality assessments and promote an increased emphasis on early collections in the continuing effort to reduce the Collection function's inventory and currently not collectible (CNC) accounts. Examiners are required to consider the collectibility of a potential tax assessment and solicit payment, including installment agreements for all unpaid balances. The keystone of our compliance activities is to promote voluntary compliance, and examinations contribute to that by having an impact on taxpayer behavior and providing a deterrent to other potentially noncompliant taxpayers.

(1) By law, the IRS has the authority to collect tax under Title 26, Internal Revenue Code, Subtitle F Procedures and Administration, which includes, but is not limited to, the following IRC sections:

• IRC 6155, Payment on notice and demand.

• IRC 6301, Collection authority.

• IRC 7801, Authority of Department of the Treasury.

(1) The Director, Headquarters Examination, is the executive responsible for providing policy and guidance for Field employees and ensuring consistent application of policy, procedures, and tax law to effect tax administration while protecting taxpayers’ rights. See IRM 1.1.16.5.5, Examination Headquarters, for additional information.

(2) The Director, Examination Field and Campus Policy, reports to the Director, Headquarters Examination, and is responsible for the delivery of policy and guidance that impacts the Field Examination process. See IRM 1.1.16.5.5.1, Examination Field and Campus Policy, for additional information.

(3) Field Examination Special Processes (FESP), which is under the Director, Examination Field and Campus Policy, is the group responsible for providing oversight and policy and procedural guidance on specialized examination processes to SB/SE Field examiners and group managers. See IRM 1.1.16.5.5.1.2, Field Examination Special Processes.

(1) Periodic program reviews are conducted by FESP to:

• Assess the effectiveness of specific programs within Examination or across the organization,

• Determine if procedures are being followed,

• Validate policies and procedures, and

• Identify and share best/proven practices.

(1) The following table lists commonly used acronyms and command codes with their definitions as used throughout this IRM:

(1) The following table lists commonly used terms and associated definitions as referenced throughout this IRM:

(1) The following table contains related IRMs which cover additional collectibility procedures that are referenced throughout this IRM.

(1) The following table includes forms and notices commonly used in the collectibility process and referenced throughout this IRM.

(1) The following table lists the Master File codes that identify installment agreement actions and their respective definitions.

(1) The examiner must determine the taxpayer’s total outstanding liabilities, and filing and payment compliance. This affects not only the scope as described below, but also affects the taxpayer’s payment options at the completion of the examination. A decision to limit the scope of the examination should be made only after all facts and circumstances have been considered. Examiners must apply the considerations described in paragraphs (2) through (11) below in all examinations where applicable.

(2) Examiners will review AMDISA to determine if the collectibility indicators are present. The code is located in the lower left section of an AMDISA.

(3) Examiners may use Form 9439, Collectibility Evaluation Form, as a job aid in evaluating collectibility if any of the following situations are applicable in the examination:

• Defunct corporation-A corporation where no assets exist to satisfy any part of the liability and there is no possibility of transferee liability. See IRM 4.11.52.2, Types of Transferee Liability.

  Note: This also applies to other business entities, such as LLCs. Some LLC liabilities can be collected through the Trust Fund Recovery Penalty (TFRP). IRM 5.1.21, Collecting from Limited Liability Companies, is used by Collection to address LLC entities and includes a section on TFRP as it applies to LLC entities. If an examiner notes high wealth accumulation by a shareholder/member, and a history of opened and closed entities, this could indicate the individual is using entities as a way to avoid tax liabilities.

• Deceased taxpayer-A deceased taxpayer where no estate exists to satisfy any part of the liability and there is no possibility of transferee liability.

• Departed taxpayer-A foreign national who has left the U.S. (with no expectation of return) and there are no identifiable assets in the U.S. to satisfy any part of the tax liability and/or collection cannot be pursued due to the terms of or lack of a tax treaty.

• Detained taxpayer-A taxpayer whose minimum period of incarceration is equal to or exceeds the normal collection period (generally 10 years from the assessment) and no identifiable assets exist to satisfy any part of the tax liability.

• Debilitating condition-A taxpayer who has minimal assets and earning potential due to advanced age, illness, or debilitating condition which permanently diminishes income producing potential.

• Other-A situation not described above in which good business sense dictates that the scope be limited. Please note that an outstanding tax balance is not in and of itself a reason to limit the scope.

(4) Examiners should evaluate (using Pre-Contact Minimum Income Probes as outlined in IRM 4.10.2.3.2, Pre-Contact Minimum Income Probes) the taxpayer’s current and future financial potential. Considerations include the following:

• What is the current financial position of the taxpayer? (The position represented on the tax return under examination is the past financial position).

• What are the taxpayer’s current earnings?

• What assets does the taxpayer currently own?

• What is the taxpayer’s future earning potential?

(5) Examiners will consider the CSED when evaluating future earning potential or future financial position. In general, Collection has ten years from the date of the assessment to collect a liability. The CSED is the last date the IRS has to collect an outstanding balance due on an account, unless the CSED is extended by case action, event, or waiver secured in connection with certain installment agreements.

(6) Examiners should consider the effect on compliance as part of the decision to limit the scope. The scope should not be limited if it would have an adverse impact on voluntary compliance. Equitable treatment of all taxpayers must be a factor in compliance considerations.

(7) Examiners should not limit the scope if indications of fraud are present or the taxpayer is manipulating assets to portray a lack of resources. The FinCEN database may be queried for transactions concerning the taxpayer. This may reveal a different financial condition than otherwise disclosed by the taxpayer. Additional information on accessing FinCEN can be found in IRM 4.26.4.5.4, Gatekeeper or Super User Procedures.

(8) Examiners should contact your Technical Services Exam Bankruptcy Coordinator if the taxpayer has filed for bankruptcy. See IRM 4.27.1, Bankruptcy, Examiner Responsibilities and Procedures.

(9) Examiners should apply the six-year enforcement period discussed in IRM 1.2.1.6.18, Policy Statement 5-133, Delinquent returns - enforcement of filing requirements, for non-filed returns. On a case-by-case basis, examiners may limit the number of delinquent returns to secure based on collectibility.

(10) Examiners must not apply Collectibility considerations to the following:

• NRP returns.

• TEFRA partnerships. However, collectibility is considered where partnership items have been converted to non-partnership items for TEFRA investors, and for BBA partnerships

• Abusive Transaction (AT) investigations. If the taxpayer under examination was identified as a client of an individual or entity authorized for an AT penalty investigation, contact the local Collection AT Coordinator. For more information on cross-functional coordination with Collection see IRM 4.32.3.4, Collection.

(11) Examiners should use professional judgment when considering the facts and circumstances to determine the scope and depth of examinations. The following examples provide guidance on applying the considerations and the resulting effect on the examination:

(1) Examiners should consider collectibility as discussed in IRM 4.20.1.2.1 and, when collectibility is an issue, a discussion must be held with the group manager. During this discussion, a decision is made to survey, limit the scope, or continue the examination. The discussion with the group manager must be documented on the appropriate lead sheet as outlined in IRM 4.20.1.2.4.

(2) The return may be surveyed based on assessment of collectibility outlined in IRM 4.20.1.2.1. Complete Form 1900, Income Tax Survey, documenting the collectibility reasons for the survey. Retain the form in the case file after approval by the group manager.

(3) The decision to limit the scope can be made during the pre-contact based on facts and circumstances. Examiners will document reasons for limitation and planned scope in the appropriate lead sheet as stated in IRM 4.20.1.2.4. For example, the examiner should list which LUQ items will be examined and the basis for the decisions. See IRM 4.10.2.7.1.3, Limiting the Scope.

(1) Inform the taxpayer(s) and/or representative at the initial examination appointment that payment options will be discussed and payment solicited during the closing conference or at the conclusion of the scheduled office examination appointment if any deficiency is recommended.

(2) Secure delinquent returns, if applicable, during the examination so the taxpayer is fully compliant to qualify for an installment agreement as stated in IRM 4.20.1.4.1.

(3) Limit the scope, as appropriate, during the examination if the taxpayer’s financial condition changes after the pre-contact. If the scope is limited, the examiner will prepare a report at the earliest opportunity. The following adjustments should be included in the examination report:

• Adjustments in the taxpayer’s favor.

• Automatic disallowances.

• Statutory adjustments.

• Other issues fully developed when the decision is made to limit the scope.

Example: During the IRP reconciliation, unreported income is identified. The taxpayer does not contest the unreported income item. Include this adjustment on your report.

(1) Field examiners must document all steps taken in the determination of collectibility on the appropriate lead sheet (or supporting workpaper referenced to the lead sheet, Form 9984, Examining Officer’s Activity Record, or RGS Case History) for all cases:

(1) Examiners should encourage taxpayers to pay online. Provide the taxpayer with Pub 5034, Need to Make a Payment? and refer the taxpayer to https://www.irs.gov/payments.

(2) The primary objective is to obtain FULL payment of the deficiency when the examination is complete.

(3) Solicit full payment for the exam deficiency and any outstanding balances due from all tax years during the closing conference or at the conclusion of the scheduled office examination appointment. TXMOD and IMFOLI (or BMFOLI) can be used to determine outstanding balances.

(4) For unagreed cases, examiners should solicit payment and explain benefits of posting an IRC 6603 deposit which stops the accumulation of interest. IRC 6603 deposits can be made using the Electronic Federal Tax Payment System (EFTPS); or by a check or money order accompanied by a written statement designating the payment as a 6603 deposit. See IRM 20.2.4.8.2, IRC 6603 Deposits, and Rev. Proc. 2005-18 for guidance regarding 6603 Deposits.

(5) Taxpayers should be informed of the following benefits of making a current payment:

• Decrease future interest which is compounded daily.

• Decrease failure to pay penalty and related interest, which accrues if the deficiency is not paid within 21 days of first notice (10 business days for $100,000 and over).

(6) Use the tiered interview to determine the taxpayer’s ability to pay and include the following dialogue:

• The total amount owed which includes tax, estimated interest, and penalties is $ amount. Are you going to pay online at https://www.irs.gov/payments or by check or money order? You can download the app "IRS2Go" and pay using your mobile device.

• If you are not able to pay in full today, what is the maximum amount you can pay?

• Can you make full payment upon receipt of the first notice? https://www.irs.gov/payments/online-payment-agreement-application offers a short term payment plan for 180 days.

(7) Examiners must discuss the taxpayer’s options for full payment before discussing other alternatives. Examiners may use Pub 594, The IRS Collection Process, to explain payment options with taxpayers. See IRM 4.18.1.6.5, OIC Filed During the Audit, if the taxpayer requests an OIC DATC during the audit. Options for full payment can include:

• Checking and savings accounts.

• Home equity loans, business loans, loans from relatives.

• Loan or withdrawal from retirement accounts (penalties may apply).

• Cash advances from credit cards.

• Liquidation of assets (sell stock, boat, etc).

• Gifts from relatives.

(8) Examiners must solicit an installment agreement if the taxpayer qualifies and cannot pay in full. See IRM 4.20.1.4.

(1) In all unpaid cases (agreed and unagreed), financial data about the taxpayer gathered during the examination must be recorded on Form 9440, Taxpayer Levy Source and Contact Information, to assist in future collection efforts. If the examiner is aware of more current financial information this may be included but should not be solicited from the taxpayer.

(2) Form 9440 is not required on fully paid cases. A case is fully paid if the tax, penalties, and interest are all paid in full, including outstanding deficiencies in other periods. Form 9440 is not required if an installment agreement is secured which will pay in full the deficiency and any other account balances within the term of the agreement.

(3) Form 9440 should not contain taxpayer identification numbers for employers or financial institution account numbers. It should only include the full names and complete addresses of the sources.

(4) Do not include information already available through IDRS or other internal sources. For example, if a taxpayer has wages on the IRPTR from prior years, this employer would not be listed on Form 9440.

(5) For IMF taxpayers, employers and financial institutions will be the primary levy sources. For BMF taxpayers, levy sources include financial institutions and accounts receivable if applicable.

(6) Check the Form 9440 box on Form 3198, Document Transmittal, to notify Exam CCP to pull the form and input.

(7) Form 9440 is saved in Case File Documents in RGS and, if applicable, placed in the paper case file on top of all other documents enclosed within the case file. See IRM 4.10.9.9.3, Forms and Other Documents Inside the Case Folder.

(8) Upon receipt of a closed case, Exam CCP will enter the information contained on the Form 9440 into IDRS using the LEVY command code.

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(2) The examiner will initiate the referral to Collection when they believe the final amount due will be agreed and the total unpaid liability will be more than the threshold amount. Field Collection will notify the examiner within 10 calendar days whether the referral is accepted or rejected. The examiner may close the case once the referral is sent. The activity record should include documentation of the referral date and response, if known at the time of closure.

(3) If the taxpayer requests an installment agreement which is beyond Examination’s criteria, see IRM 4.20.1.4.7.

(4) Any informal consultations can be coordinated by the Examination manager and the Collection manager using the buddy system as described in Memorandum of Understanding Between SB/SE Field Collection and SB/SE Field Examination.

(1) For agreed closures, the following should be documented on the appropriate lead sheet as stated in IRM 4.20.1.2.4:

• Any payment submitted,

• Installment agreement discussion, including why one was not obtained,

• Mandatory referral made in accordance with IRM 4.20.1.3.3, and response from Collection, if known at time of closure,

• If unpaid, taxpayer was advised to respond to the first notice,

• Whether or not Form 9440, Taxpayer Levy Source and Contact Information was completed.

(2) For unagreed closures, the following actions should be taken and documented on the appropriate lead sheet as stated in IRM 4.20.1.2.4:

• The examiner should advise the taxpayer of IRC 6603 deposit procedures and complete Form 9440. The taxpayer should also be reminded that IRC 6603 deposit does not prevent them from exercising their appeal rights.

• If the taxpayer disagrees with some, but not all issues, the examiner should encourage the taxpayer to enter into a partial agreement and follow the steps outlined above for securing payment on the partial agreement.

(1) To qualify for an installment agreement, taxpayers must be current in filing of all required tax returns, including employment and excise tax. All required period deposits (FTDs and/or estimated payments) must be current. Inform the taxpayer they must remain tax compliant for the entire term of the installment agreement, or it will default. Use the following IDRS command codes to determine if the taxpayer is compliant, including cross-referenced taxpayer identification numbers displayed on Master File:

• Employment tax returns,

• Information returns,

• Highway use tax returns.

(2) Installment agreements must include the taxpayer’s total amount owed for all years, including civil penalties (MFT 13, 35, 55).

• Exam deficiencies can be added to an existing installment agreement if the total amount remains within Exam’s criteria as shown below. If the taxpayer is still in business with employees, unpaid employment tax or other BMF liabilities cannot be combined in an exam installment agreement. To revise an existing installment agreement, write "Revised Agreement" in red on top of Form 433-D, Installment Agreement.

• A payment can be made by the taxpayer to reduce the balance to within the installment agreement criteria. This payment is processed as an advance payment of deficiency. See IRM 4.20.1.3.1.1.

(3) Installment agreements secured by Examination are pre-assessment agreements and limited to:

• Individuals, including sole proprietorships, without delinquent employment taxes up to $50,000,

• Out-of-business BMF entities up to $25,000,

• Corporations and other BMF entities up to $25,000.

(4) Examiners are authorized to set up two types of installment agreements. The dollar criteria stated below applies to unpaid balances for all tax years. Authorized installment agreements are:

• Guaranteed Installment Agreements - For individual taxpayers with income tax deficiencies of $10,000 or less (excluding penalties and interest) that can be paid within 36 months. See IRM 5.14.5.3, Guaranteed Installment Agreements, for guidance.

• Streamlined Installment Agreements - For taxpayers with tax deficiencies of $50,000 or less (including tax, penalties, and interest) that can be paid within 72 months. See IRM 4.20.1.4.3, for guidance.

(5) The taxpayer must be able to pay the minimum acceptable payment as stated in IRM 4.20.1.4.3, for streamlined installment agreement and IRM 4.20.1.4.4, for guaranteed installment agreement. However, the examiner should encourage the taxpayer to offer the maximum amount they can pay at the examination closing and each month thereafter.

(1) Encourage the taxpayer to utilize the online payment agreement (OPA). See IRM 21.2.1.57, Online Payment Agreement (OPA) for IMF Debts, and IRM 21.2.1.57.1, Online Payment Agreements for Certain BMF Debts. Online agreements offer reduced user fees. Refer interested taxpayers to Payment Plan on the Pay tab of https://www.IRS.gov and provide Pub 5123, Online Payment Agreement. When the taxpayer completes the online payment application, the examiner should confirm input of the OPA by requesting confirmation from the taxpayer or verify using another method. Complete Line 412 on Form 5344, Examination Closing Record, with “I” for installment agreement secured.

(2) The examiner must complete the following when a "How to Pay Your Taxes" flyer (Form 4549 attachment) generated by RGS is received from the taxpayer:

• Determine if the taxpayer’s offered amount meets Exam’s criteria for securing an installment agreement. If the taxpayer owes $25,000 or less, the examiner should transfer the completed information from the flyer to the applicable lines on Form 433-D, Installment Agreement. Refer to IRM 4.20.1.4.5 (5) for processing instructions. Attach the "How to Pay your Taxes"” flyer to Form 433-D.

  Note: Form 433-D does not require the taxpayer’s signature unless the taxpayer owes over $25,000 where a Direct Debit Installment Agreement (DDIA) is required to avoid Notice of Federal Tax Lien (NFTL) determination. See IRM 4.20.1.4.3.2.

• Follow instructions for Form 9465, Installment Agreement Request, in IRM 4.20.1.4.7 if the taxpayer does not qualify for an installment agreement under Exam’s criteria.

(3) A completed Form 9465 secured from a taxpayer can be processed by Collection as an installment agreement if all information is correct and the taxpayer’s offered amount meets Exam’s criteria.

(1) Streamlined installment agreements are termed "streamlined" because they do not require a financial statement from the taxpayer. Therefore, for simplicity the term installment agreement used in this section will imply streamlined installment agreement.

(2) Installment agreements may be secured where the total unpaid balance (including interest and penalties) of assessments (all years) does not exceed $50,000 and can be paid off within a 72 month period and prior to the CSED.

(3) Agreements of $25,000 or less can be secured for:

• Individuals, including sole proprietorships, without delinquent employment taxes,

• Out-of-business BMF entities,

• Corporations (Form 1120) and other BMF entities including Form 1065 late filing penalty.

(4) The following limitations apply for agreements of $25,001 - $50,000:

• Corporations still in business are not eligible,

• Payment must be made by direct debit (IRM 4.20.1.4.3.2) or payroll deduction (IRM 4.20.1.4.3.1) to avoid requirement for NFTL (Notice of Federal Tax Lien) determination, and

• The taxpayer must have not defaulted on an installment agreement in the past 12 months. The examiner can verify the taxpayer has not defaulted by checking IDRS for absence of TC 971/AC 163.

  Caution: Individual taxpayer filing Form 1040, U.S. Individual Income Tax Return, with Schedule C, E, or F businesses are eligible for streamlined installment agreements IF the related BMF returns (Forms 940/941/2290) are current not only in filing, but also in making FTD payments.

(5) The minimum acceptable payment:

• Is computed by dividing the total amount of tax, accrued interest, and penalties by 72,

• Is the monthly amount to be paid over 72 months, and

• Must allow for full payment by the CSED.

(6) If the taxpayer has the financial ability to pay off the balance due in less than a 72 month period, the lesser period should be appropriately considered. However, the taxpayer may be granted an installment agreement based on 72 months even if they are able to fully pay their accounts.

(7) Examiners should inform taxpayers of the user fees the IRS is required to charge associated with an installment agreement. Installment Agreement User Fees can be found at http://serp.enterprise.irs.gov/content/irm-supplements/ia-user-fee-codes.html. User fees also apply to revised agreements.

(8) The fees will be taken from the first installment payment. Examiners should advise the taxpayer that if the first payment is less than the user fee, the first reminder notice they receive will be for the user fee. The user fees are non-refundable in most situations.

(1) IRC 6159, Agreements for payment of tax liability in installments, provides that certain taxpayers who meet specified criteria are legally entitled to an installment agreement. The provision applies to individual taxpayers only.

(2) Guaranteed installment agreements are for tax only up to $10,000 that can be paid in 36 months. Taxpayers qualifying for a guaranteed installment agreement would generally also qualify for a streamlined installment agreement. Accordingly, examiners should use streamlined installment agreement procedures to process guaranteed installment agreement. The minimum payment for a guaranteed installment agreement is determined by dividing the balance due by 36.

(3) See IRM 5.14.5.3, Guaranteed Installment Agreements, for procedures.

(1) Determine total amount owed: Use SUMRY to determine if the taxpayer has any outstanding tax liabilities to combine with the pre-assessed amount to calculate the installment agreement limitation. The total amount of tax, penalty, and interest as of the date the form is completed is included in the Amount Owed As Of box. Only one installment agreement is allowed per taxpayer; therefore, multiple years are combined for the amount owed.

(2) The taxpayer may select any installment payment date between the 1st and 28th day of each month.

(3) Form 433-D, Installment Agreement can be completed using RGS. See Completing IA Using RGS on the Installment Agreements by Field Examination page in the Collectibility, Bankruptcy and Other Topics book of the Exam Procedures Knowledge Base.

(4) Complete all line items on Form 433-D unless noted otherwise. Line items requiring additional explanations are noted below:

1. Kind of Tax - (form number) - for example 1040 or 1120.

2. Tax periods - all periods covered by the agreement (for example: 2017 and 2018)

3. Date of Increase/Decrease - use only when a taxpayer’s financial situation will change allowing an increase in the set payment amount or requiring a decrease to the amount.

   Example: The taxpayer is able to pay $300 on the balance each month. In three months he will receive a pay raise and will then pay $400 per month. Enter the date the amount will change, the amount of increase or decrease, and the new installment amount.

4. Additional Conditions- type in Print your SSN, tax year, and form number on all checks submitted for payment. Make checks payable to United States Treasury.

5. Direct Debit- only complete if the taxpayer requests payments by direct debit.

6. Debit Payments Self-Identifier- check the box if the taxpayer is unable to make debit payments. The Debit Payments Self-Identifier section is used for low-income taxpayers to self-identify for fee reimbursement if they are unable to make electronic debit payments.

7. Your signature- for taxpayer’s signature, date, title if corporate officer, spouse’s signature. Taxpayer signature is only required for DDIA.

8. Use the following table to complete the FOR IRS USE ONLY section:

FOR IRS USE ONLY	ENTRY	REFERENCE
Agreement Locator Number	First 2 digits = 06 for installment agreement not including direct debit Installment Agreement First 2 digits = 03 for Direct Debit Installment Agreement Last 2 digits = 32	Exhibit 5.14.1-2, Installment Agreement Locator Numbers
Check the appropriate boxes	RSI 1 no further review	Since installment agreements secured by Examination are not partial pay installment agreements (PPIA), no review is necessary
Agreement Review Cycle	Leave blank	N/A
Earliest CSED	MM/DD/YYYY	Earliest CSED from IMFOLT/ BMFOLT
Check box if pre-assessed modules included	Check box	All exam installment agreements are pre-assessed
Originator’s ID number	XXXXXXXXXX	Examiner badge number
Originator Code	61	Exam Streamlined Agreement
Name	Examiner name	self-explanatory
Title	RA or TCO	self-explanatory
A Notice of Federal Tax Lien	May Be Filed if This Agreement Defaults	IRM 5.14.1.2(1), Installment Agreement and Taxpayer Rights
Approval Signature	Examiner may sign; group manager signature is not required	Signatures are not required

(5) Provide taxpayer with instructions on Where to Mail Payments at: http://serp.enterprise.irs.gov/databases/who-where.dr/campus-balance-due-accounts.html?bod=3&state=All&stateRow=1&b1= until CP521 notices are received. Taxpayers can also make payments online. Provide Part 2 of Form 433-D, Taxpayer Copy, including taxpayer instructions.

(6) Examiners will EEFax secured installment agreements to CSCO Memphis at 855-381-6514. The fax cover sheet accompanying the installment agreement should include the following information:

• Whether the installment agreement is a direct debit installment agreement (DDIA) or non-DDIA.

• Examiner’s function: Field Exam or Specialty Tax.

(7) Notate "EEFaxed to 855-381-6514" on top of the installment agreement form and document Form 9984, Examining Officer’s Activity Records, or RGS Case History. For paper case file closures, include the original installment agreement form in the workpapers. For electronic case file closures, follow the applicable electronic procedures for saving scanned documents.

(1) IRC 7122(e), Compromises, provides appeal rights to taxpayer whose request for an installment agreement is rejected. Examination does not have the authority to reject installment agreements. If a taxpayer requests an installment agreement that is not within the examiner’s scope, see IRM 4.20.1.4.7.

(1) If a taxpayer requests an installment agreement that does not meet Exam’s criteria, the examiner should solicit Form 9465, Installment Agreement Request, and EEFax the form to Compliance Services Collection Operations (CSCO) at 855-381-6514 for processing.

(2) If not already completed, and the taxpayer qualifies, Form 3177, Notice of Action For Entry On Master File, must be input for a pending installment agreement. See IRM 4.20.1.4.2.1.