USA Is suspended PPIA payments during COVID a tolling event?


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Thanks in advance for any insight you can provide. I do have an accountant for me and my small business but we generally just emphasize tax preparation and I don’t think CSED’s are her area of focus.

Anyway, I have a long-term PPIA with the IRS that I have been chipping away at for some years now. I’m in good standing as far as I know and have been current with my taxes since getting into that trouble years ago. Two CSED’s have come and gone. The next one is in 12/2020 according to information I have.

It’s a good thing that the IRS kindly suspended installment arrangement payments during a few COVID months (though I still made my payments since it made me nervous not to), but did that suspended payment period act as a tolling event for a PPIA in progress or will upcoming CSED’s be unchanged?
 
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kirby

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Sorry, that is a legal question that you'll need to post in a legal forum.
 
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How is that a legal question? It's solely based on the IRS and events it considers tolling events.
 
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Until it is challenged, we (practitioners) simply have no guidance to address your scenario. It would take an attorney (with access to legal resources, such as LexisNexus) to do some tax court research and see if they could find a case that addresses this question. The brief online search I did through IRS.gov did not yield any results for this question.

Therefore, Kirby is right. To answer this question, you'd need to find a case similar to your scenario and see how the IRS resolved it. We can only speculate from here, unless you'd like to be first in line to challenge them.

My guess? The IRS would argue the suspended period does indeed act as a tolling event, and you're now looking at an extended CSED. You could take them to court and argue to the contrary, since you kept making payments. But that wouldn't be worth your money nor time. So I recommend you keep making payments until you feel comfortable you have a legal basis for claiming CSED (and be prepared to back it up).
 
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It looks like the IRS did not use any COVID-suspended PPIA payment period as a tolling event. A CSED due to expire around 12/31/2020 did just that. Thanks for everybody's input.
 
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It looks like the IRS did not use any COVID-suspended PPIA payment period as a tolling event. A CSED due to expire around 12/31/2020 did just that. Thanks for everybody's input.
I truly appreciate you letting us know. Thanks!
 
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