If you don't report income that you should have reported, and it's more than 25% of the gross income shown on the return, or it's attributable to foreign financial assets and is more than $5,000, the time to assess tax is from the date you filed the return.
If you don't qualify for an IA through OPA, you may also request an IA by submitting Form 9465, Installment Agreement Request, with the IRS.
WHY THE IRS REJECTS INSTALLMENT AGREEMENT REQUESTS. The IRS typically rejects an installment agreement request for one of three reasons. If the IRS determines that your living expenses do not fall under the category of “necessary,” your agreement will more than likely be rejected.
The IRS considers extravagant expenses as those that include charitable contributions, private school funding and hefty credit card payments. In addition, if you fail to provide accurate information on Form 433-A, Collection Information Statement, you can expect your agreement to be rejected.
For more information about TAS and your rights under the Taxpayer Bill of Rights, go to TaxpayerAdvocate.IRS. Attach Form 9465 to the front of your return and send it to the address shown in your tax return booklet.