IRS Installment Agreements & Amended Returns

Technical topics regarding tax preparation.
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Hello,

Forgive me if this topic has been already posted. There is a lot of information out here. I'm a CPA specializing in SUT. However I have a question related to personal income tax returns, amended returns and installment agreements. Specifically, there is a current federal tax determination for a friend for years 2019 & 2021. 2019 needs to be amended. The return is not filed correctly and amending it would definitely reduce the overall tax liability. I am pulling that filing together now. 2021 we agree that the tax is owed. Can an installment agreement be in place and only apply to 2021? My hunch is no, payments would first go to satisfy 2019 liability and then 2021. Is that correct? Would agreeing to a payment plan on the 2021 notice negate the ability to file an amended return in the meantime for 2019? or even 2021, should something come to light? Of course the 2021 notice is asking for a decision on a payment plan by 12/11/2022. I know, I know, why didn't the friend ask sooner...

Thank you for for any insight or recommendations. You don't know what you don't know!

Regards
Nicole
 

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