- 8 - proposed three alternatives to collection. We address each seriatim. Currently Not Collectible Generally, currently not collectible (CNC) status may be available when a taxpayer has no ability to make payments. 2 Administration, Internal Revenue Manual (CCH), sec. 5.16.1.1, at 17,803 (2000). A taxpayer’s ability to make payments is determined by calculating the excess of income over necessary living expenses. 2 Administration, Internal Revenue Manual (CCH), sec. 5.16.1.2.1, at 17,804 (2000). CNC status may be available based on “hardship” if the levy action would prevent the taxpayer from meeting necessary living expenses. Petitioners submitted to the settlement officer certain personal financial information in support of their request for CNC status for the cumulative liability. The settlement officer concluded that petitioners had the ability to make monthly payments and that CNC status was not appropriate. Petitioners do not challenge the settlement officer’s conclusion as to their ability to make some payments toward their cumulative liability; indeed, petitioners’ proposed offer in compromise, involving payments of $180 per month, would belie any such claim. Petitioners clearly had some ability to make payments toward the cumulative liability. As a result, petitioners were not eligible to have the cumulative liability classified as CNC. WePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011