7.1.1 General Principles

Most legal aid clients will be candidates for “Currently Not Collectible” (CNC) status. A taxpayer may be placed in CNC status if collection would cause undue hardship by leaving the taxpayer unable to meet necessary living expenses.1 A levy on wages must be immediately lifted if the taxpayer is placed CNC status.2 A taxpayer may receive CNC status even if there are unfiled tax returns.3

• 1I.R.M. 5.16.1.1, .2.9.
• 2I.R.C. § 6343(e); I.R.M. 5.16.1.2.9(7).
• 3Vinatieri v. Comm’r, 133 T.C. 392 (2009); I.R.M. 5.16.1.2.9, 8.22.7.7(4).