The IRS has the ability to disapprove more payment plans but the criteria are not clear. All I could find was
this statement from the IRS' site saying they can be rejected after which the debtor has 30 days to make arrangements before collections begin:
While
this website says anyone who meets these four criteria:
Automatically qualifies but there is not an equivalent set of criteria for disqualification.
I believe Phil meets #1 because he files his returns but requests a payment plan rather than paying in full but eventually he will be unable to meet #2 - even if he meets it right now (I have no way of knowing if this is true) the sheer number of payment plans will eventually be so large that some will need to be on repayment periods of greater than three years. When that happens, like Kosher Dill ninja'd me with, it is at the IRS' discretion and their criterion will be, can he reliably make his payments?
Now for the less exciting news. Phil's inability to make his tax payments or get approved for a payment plan will not automatically result in the IRS garnishing his wages or seizing his property. They could just as easily file a lien on his condo, then just wait until he sells it or passes away and collect their money from the proceeds/estate. This gets even more boring since Phil has said he plans to spend the rest of his life in that place and I believe him. It's not like he cares about Kat possibly losing it to the IRS after he dies.
EDIT: The IRS has two alternatives to the installment plans Phil is on if/when he can no longer qualify for regular repayment plans.
The first is called an
offer-in-compromise (yes really..... he would get out of debt thanks to OIC). Under this plan, if Phil could show he would probably never be able to pay the debt in full, he could come up with his own proposal for a settlement and installment plan. There is no guarantee it would be approved; the IRS has
a tool that lets people see if they qualify for an OIC but there are too many unknowns in Phil's finances to figure out if he'd qualify. More importantly, I cannot tell he could apply it to multiple years of back taxes or only a single payment plan at a time.
The second, which if I read it right he is extremely unlikely to get, is a
partial payment repayment plan. It's exactly what it sounds like, a payment plan that lets the debtor fulfill the debt for less than the full amount. The reason I say he is extremely unlikely to get it is that it is only available to people who have no outstanding back taxes. We all know that's not happening unless he gets a six- or seven- figure inheritance.