Currently Not Collectible Status (CNC)
The Currently Not Collectible Status generally refers to those accounts that the IRS collection function has removed from ‘active inventory’. The reasons for doing this are quite numerous. The IRS may simply be unable to locate the taxpayer or their assets, the taxpayer may have moved to another country where their assets cannot be reached, or they may have died and the estate presents no collections potential. The more commonly-known basis for CNC is hardship.
If IRS Collections determines that the delinquent taxpayer has limited assets or income and that levy action would create a hardship, the liability may be ‘shelved’ as CNC. IRS policy, however, requires a determination whether levies would result in ‘actual hardship’, not ‘mere inconvenience’. This determination can vary in complexity by the Collections venue of the file. That is, Revenue Officers approach this determination very differently than the Automated Collections Service. And, both might approach the file differently than the Appeals Office.
The benefits of the CNC are the abatement of enforcement, the relatively straightforward proposal process and the potential for savings if the file remains in CNC through the expiration of the debt. The drawbacks are the persistence of the lien and the risk of return to collections due to a perception of an improved financial situation.