Just to get us on the same page, see this from above:
Now, you should be aware that any refund generated from a current year (involving him) COULD be attached because of a previous tax year issue
OK, so I understand you saying filing together will not make me liable for past as we did not file together in the years he owes back taxes. Moving forward and filing jointly may void any refund coming to us but rather being applied to back taxes. As long as he remains current with his taxes now we should not have any issues, correct?
(1) If you did not file jointly before you are not jointly and severally liable.
And, as we discussed above.
(2) That, refunds from filing jointly going forward (and other places where you have joint ownership or liability) COULD be affected because of HIS liability from past years.
What your accountant is saying (I can only speculate) is that by asking for this payment plan - based on a joint return filed this year - when one of the two parties here (your husband) still has a liability from previous years, the plan might not go through.
By asking for a payment plan plan on this JOINT return you will NOT have kept things separate.
(DOESN'T MAKE YOU LIABLE for his past separately filed liabilities, but now you and he TOGETHER are asking for a payment plan on only $8,000, when HE owes more than that.)
This is the same logic that says they could attach any future refund going forward from a JOINT return.
I think you have two options:
(1) Ask for a payment plan that includes the $8,000 plus whatever is owed by him.
(2) File separately and ask for the payment plan based on what only you owe.