Where an offer provides for the taxpayer to make deferred or installment payments, including payments pursuant to a collateral agreement, the taxpayer ordinarily should agree to entry of judgment for the full amount of the Government's claim. The settlement should also provide that the Government will file a satisfaction of judgment when the taxpayer has completed all obligations under the settlement (i.e., paid the amount due under the settlement, including any amount due under a collateral agreement). The settlement should also provide that the IRS will maintain any federal tax liens securing the liabilities being compromised until the taxpayer makes the final payment due under the settlement. Once the taxpayer has made the final payment, the IRS will release the liens.

[updated April 2018]