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Repeater Cases
The Internal Revenue Manual provides the following guidelines for negotiating with in-business repeaters:
"... if taxpayers:
• are in business,
• have three or more trust fund bal dues assigned to the collection field function, then, they are considered
"repeaters." These taxpayers may not -- immediately -- be granted installment agreements.
• file all appropriate returns (so that they are in compliance with all filing requirements); then, they are no
longer considered repeaters and may qualify for installment agreements." [IRM 5.14.7.2 ]