The answer to this question is both. The IRS will allow an installment payment amount based upon the taxpayer’s current ability to pay. If the taxpayers financial picture indicate he or she will have the opportunity to earn more going forward, the IRS will revisit the installment agreement payment amount in the future. If the taxpayer is submitting an Offer in Compromise, the IRS may require a higher offer amount or require a collateral agreement with respect to the taxpayer’s earnings that is tied to the offer.