Currently Not Collectible: Hardship and Collection Relief

Categories: IRS CE, IRS Resolution
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About Course

When a client cannot afford to pay a federal tax liability, Currently Not Collectible (CNC) status under IRC §6343 provides one of the most effective — and frequently underutilized — tools available in IRS collection defense. This 2-CE-hour course provides a comprehensive, practice-oriented examination of CNC status: its statutory basis under IRC §6343 and IRM 5.16.1, eligibility criteria, the financial disclosure process using Forms 433-A and 433-F, and the long-term strategic implications of CNC status — including its effect on the Collection Statute Expiration Date (CSED).

Across four structured modules, participants apply IRS Collection Financial Standards to evaluate income and expenses, analyze asset equity using the IRS quick-sale valuation methodology, build a complete CNC application package, and develop strategies for maintaining CNC status through the IRS annual review cycle. The course concludes with Circular 230 compliance obligations specific to CNC representations and practitioner guidance on transition planning when client income changes.

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What Will You Learn?

  • Identify the statutory and regulatory basis for CNC status under IRC §6343 and the IRM
  • Analyze taxpayer financial statements using IRS Collection Financial Standards
  • Apply quick-sale value methodology to asset evaluation for CNC purposes
  • Calculate Collection Statute Expiration Dates across multiple independent tax periods
  • Develop a long-term CNC maintenance and transition strategy for clients

Course Content

Module 1 – CNC Overview, Legal Framework, and Initial Determination
This module establishes the statutory and regulatory foundation for Currently Not Collectible status, examining IRS authority under IRC §6343 and IRM 5.16.1. Participants learn how CNC compares to installment agreements and Offers in Compromise, how the hardship standard is evaluated, and the critical effect of CNC status on the Collection Statute Expiration Date.

  • CNC Overview, Legal Framework, and Initial Determination

Module 2 – Financial Analysis and CNC Application
This module covers the financial disclosure process central to any CNC application, including selection and preparation of Form 433-A or Form 433-F based on case circumstances. Participants apply IRS Collection Financial Standards — national and local — to calculate net monthly income, document allowable expenses, and build a complete CNC submission package.

Module 3 – Asset Analysis and CNC Determination
This module examines how the IRS evaluates taxpayer assets in a CNC determination, including quick-sale value methodology for real property, retirement account analysis, and vehicle equity under Collection Financial Standards. Participants develop strategies for borderline cases and learn how federal tax lien implications affect the CNC analysis.

Module 4 – Maintaining CNC Status and Transition Planning
This module addresses the ongoing responsibilities of CNC representation: the IRS annual income review process, strategies for managing the transition from CNC to an installment agreement when client income increases, and the Circular 230 due diligence obligations that apply throughout the representation.

Final Assessment – Currently Not Collectible: Hardship and Collection Relief
You have completed a comprehensive review of Currently Not Collectible status, covering the statutory framework under IRC §6343, the financial disclosure process using Forms 433-A and 433-F, asset equity analysis, and long-term CNC management strategies. You are now prepared to demonstrate your understanding of the key concepts. The following final examination assesses your knowledge of the material covered in all four modules. A passing score of 70% is required to successfully complete the course.

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