Can an installment agreement for unpaid payroll taxes use an increasing installment payment plan with a balloon payment at the end?
Have you completed a 433-A OIC for this client!!???
Because it is payroll tax returns I would be filing the 433-B and requesting installment payments on the 433-D. The deficiency is approx. 6.5m with taxes, interest and penalties. The company can pay this and the questions I have what would be the maximum time in years for payment? Form 433-D does allow for increasing payments so some customized amortization schedule could be used it appears. Would the IRS consider a balloon payment? For example, let’s say I propose 5 years at $70k a month with the balance due at the end or 5 years or longer?