Small individual tax issues, yes the IRS will be nice and attempt at a structuring of paying back ALL the debt.
But The IRS is NOT going to give you a break. Their job is to collect as much of the debt as possible. And their attitudes are different if it’s employment taxes or employee withholding rather than your personal income tax. They go after employment taxes MUCH harder than personal income tax.
You need to talk with a tax attorney first about the type of tax and what you can structure.
Never would I go to the IRS and work out a payment plan without being armed with professional tax knowledge regarding options. Going to the IRS first is horrible advice unless you are a tax professional familiar with the process.