7.2.7 Denials or Terminations

Once the installment agreement is approved, the IRS and the taxpayer are bound by the agreement unless the taxpayer misses a payment, fails to file tax returns, provided inaccurate information during the negotiations, or has a changed financial condition. Denials or terminations of installment agreements may be appealed using Form 9423 and later reviewed in Tax Court under the abuse of discretion standard. The IRS will reinstate an installment agreement one time upon payment of a reinstatement fee. A taxpayer who is in danger of default on an installment agreement should contact the IRS. It is possible to get a temporary hold on payments.