Every collection resolution case begins with the same document: a completed Collection Information Statement. Whether the goal is an Offer in Compromise, a structured installment agreement, or a Collection Due Process hearing argument, the IRS will not move toward any resolution without a clear picture of what the taxpayer owns, earns, and spends. That picture comes from Form 433-A for individuals, or Form 433-B for business entities. Getting these forms right, using the correct version, documenting every number with supporting evidence, and applying the National and Local Standards accurately, is the foundational work of collection representation. An error in the financial disclosure flows directly into a flawed Reasonable Collection Potential calculation and, ultimately, into a rejected offer or a payment plan the client cannot sustain.
This guide is written for tax practitioners handling collection resolution cases: enrolled agents, CPAs, and attorneys representing clients before IRS Collection, as well as PTIN-only preparers who need to understand the structure of the financial disclosure before deciding whether to refer a client to a credentialed representative. It covers the three CIS variants and when each applies, the section-by-section content of Form 433-A, the National and Local Standards expense analysis, asset equity calculations, documentation requirements, common IRS rejection triggers, Form 433-B differences for business cases, and how the completed CIS feeds into each resolution strategy.
All regulatory figures, form version references, and IRS standards in this guide should be verified at IRS.gov before relying on them in client engagements. IRS allowable expense standards, form revisions, and program procedures are subject to change. This guide is informational and does not constitute legal or tax advice.
What a Collection Information Statement Is and When the IRS Requires It
A Collection Information Statement is a sworn financial disclosure document that gives the IRS a complete picture of a taxpayer's assets, liabilities, income, and expenses. The IRS uses this information to calculate the taxpayer's Reasonable Collection Potential: the maximum amount the IRS could realistically recover from the taxpayer before the Collection Statute Expiration Date, either through asset liquidation or future income. The CIS is not a form you fill out once and move on. It is the evidentiary foundation of every collection resolution argument, and its accuracy determines whether the resolution strategy the practitioner recommends is actually available.
The IRS requires a CIS in three distinct collection contexts. Each context has different stakes and different documentation standards.
Offer in Compromise submission
An OIC under IRC Section 7122, Doubt as to Collectibility, requires Form 433-A OIC (for individual taxpayers) or Form 433-B OIC (for businesses) as part of the submission package. The IRS uses the CIS to calculate the Reasonable Collection Potential, which establishes the floor amount it will accept for the offer. If the offer amount is below the calculated RCP, the IRS will reject the offer. The OIC version of Form 433-A is longer and more detailed than the standard version. Using the wrong form version is itself a rejection trigger. See the IRS Offer in Compromise preparer guide for the full OIC workflow, credential requirements, and when an OIC is the appropriate resolution path.
Installment agreement financial analysis
For installment agreements over certain balance thresholds, or when the IRS is not willing to grant a streamlined or non-streamlined agreement without financial review, the IRS will request Form 433-A (or Form 433-F, a shorter version used in some telephone and correspondence IA cases). The financial analysis determines whether the requested monthly payment is consistent with the taxpayer's actual disposable income after allowable living expenses. A practitioner who submits an IA request with a monthly payment that cannot be supported by the financial disclosure risks either rejection or an IRS-imposed payment calculation that is higher than the client can sustain. See the installment agreement preparer guide for IA types, thresholds, and payment calculation mechanics.
Collection Due Process hearing financial documentation
When a taxpayer requests a Collection Due Process hearing in response to a Final Notice of Intent to Levy or Notice of Federal Tax Lien filing, the taxpayer may propose a collection alternative at the hearing, including an OIC or an installment agreement. Proposing a collection alternative at a CDP hearing requires submitting the appropriate CIS to support the alternative. A CDP hearing where the taxpayer proposes an OIC but has not completed a Form 433-A OIC is unlikely to result in an accepted alternative. See the CDP hearing guide for tax preparers for the 30-day appeal window and the full CDP workflow.
The Reasonable Collection Potential calculation
The RCP is the IRS's mathematical estimate of what it can collect from a given taxpayer. It has two components: the net realizable equity in all assets (quick-sale value of assets less secured liabilities), and the future income stream (monthly disposable income after allowable expenses, multiplied by a factor that reflects the collection window). The CIS is the source document for both components. An overstated expense or an omitted asset changes the RCP calculation, which changes whether a proposed offer is above or below the acceptable threshold. Practitioners who complete the CIS without understanding how it feeds into the RCP calculation are producing financial disclosures that may not serve their clients' interests.
Practitioners preparing Form 433-A (OIC) or 433-B (OIC) for an offer submission can find a complete RCP calculation workflow, including the 2026 Collection Financial Standards lookup process and multiplier selection, in our Offer in Compromise: RCP Financial Analysis guide.
Form 433-A vs. Form 433-A OIC vs. Form 433-B: Which Form for Which Situation
VERIFY CURRENT FORM VERSIONS AT IRS.GOV BEFORE FILING
Using an outdated revision of any 433-series form for an OIC submission will cause the IRS to return the offer without processing. The IRS updates these form revisions periodically. Always download the current form directly from IRS.gov immediately before completing and submitting the package. Do not use a saved copy from a prior engagement. A form revision number that does not match the current IRS-published version is grounds for return without review.
The 433 series contains three distinct forms serving three distinct functions. Using the wrong one is among the most preventable rejection triggers in collection practice, and it is more common than practitioners expect. The reason is not carelessness: the forms look similar, the IRS uses similar names for them, and older versions of the forms remain in circulation in practice management software that has not been updated. Knowing which form to use, and confirming the current revision before every submission, is a basic quality control step.
Form 433-A: Collection Information Statement for Wage Earners and Self-Employed Individuals
Form 433-A is the standard CIS for individual taxpayers. It is used when a Revenue Officer requests a financial disclosure for an active collection case, when a taxpayer requests a non-streamlined installment agreement that requires financial analysis, or in CDP hearing proceedings where the taxpayer proposes a collection alternative short of a formal OIC. Sole proprietors who report business income on Schedule C use Form 433-A rather than Form 433-B, because a sole proprietor and the business are the same legal taxpayer.
The standard Form 433-A is shorter than the OIC version and does not include the equity-calculation sections specific to RCP analysis. This is the correct form for installment agreement and Revenue Officer contexts. It is not the correct form for an OIC submission.
Form 433-A (OIC): Collection Information Statement for Wage Earners and Self-Employed Individuals (OIC version)
Form 433-A OIC is the version required for Offer in Compromise submissions by individual taxpayers. It is a distinct form from the standard Form 433-A, with additional sections that provide the IRS with the detailed asset equity and income information needed to complete the RCP calculation. The OIC version asks for more granular asset detail than the standard version and includes sections for documenting dissipated assets. As of the date of this guide, the current revision of Form 433-A OIC is Rev. 4-2026, but verify the current revision at IRS.gov before submitting: the IRS updates revision dates, and using an outdated revision for an OIC will cause the offer to be returned without processing.
When a practitioner is preparing an OIC package, confirming the current revision number of Form 433-A OIC at IRS.gov is not optional. The current revision is the only acceptable version for submission.
Form 433-B: Collection Information Statement for Businesses
Form 433-B is required when the taxpayer is a business entity: a partnership, corporation, or LLC taxed as an entity. It documents business assets, accounts receivable, monthly business income and expenses, and outstanding liabilities. Like the individual series, there is a Form 433-B OIC version for use in OIC submissions by business entities, distinct from the standard Form 433-B used in Revenue Officer and installment agreement contexts.
When a client owns a business that also has tax liabilities, both Form 433-A (for the individual) and Form 433-B (for the business) may be required in the same case. This is common in trust fund recovery penalty situations, where the IRS has assessed or may assess the business owner individually for the unpaid employment taxes of the business. Practitioners must evaluate the full picture: individual liabilities, business liabilities, and any potential TFRP assessment before structuring the resolution approach.
Form 433-A Section-by-Section: What the IRS Is Looking For
The following walkthrough covers the primary content areas of Form 433-A as used in both standard and OIC contexts. Because the OIC version contains additional equity-calculation sections not present in the standard version, practitioners should read this alongside the current form instructions at IRS.gov. The structure below reflects the major information categories the IRS reviews; specific section numbering and layout should be verified against the current form version.
Personal information and filing history
The opening section establishes identity: the taxpayer's name, Social Security number, date of birth, address, and marital status. For married taxpayers, the IRS requires information for both spouses, including the non-filing spouse's income and assets, even if only one spouse has the tax liability. This is one of the most commonly overlooked requirements. The IRS will use community property rules or equitable analysis to evaluate whether the non-filing spouse's income and assets are available to satisfy the liability. Omitting a spouse's financial information from Form 433-A when the taxpayer is married is a deficiency that will either cause return of the form or produce an inaccurate RCP calculation.
The June 2026 revision (Rev. 6-2026) of Form 433-A expanded the dependent reporting section to accommodate up to five dependents on the main form. If a client has more than five dependents, attach a supplemental statement listing the additional dependents with the same information required by the form. Verify current form capacity at IRS.gov; download the current Rev. 6-2026 form before filing.
The filing history section asks whether all required returns have been filed for the years at issue and for prior years. A client with unfiled returns will not be considered for OIC or any collection alternative until they are in filing compliance. If unfiled returns exist, confirm they are submitted and processed before preparing the CIS.
Employment and business income
This section documents the taxpayer's monthly income from all sources: wages, salary, self-employment income, rental income, business distributions, Social Security benefits, pension and retirement distributions, and any other regular income. For W-2 employees, the practitioner documents the employer, gross monthly income, and pay frequency. For self-employed individuals and sole proprietors, the form requires documentation of gross business receipts and ordinary and necessary business expenses to arrive at net self-employment income.
The IRS cross-references income figures on Form 433-A against wage and income transcripts, business tax returns, and third-party information returns. A reported monthly income figure that is inconsistent with transcript data, either higher or lower, will trigger a follow-up request. Practitioners should pull the client's wage and income transcript before completing this section and confirm that every income source reported on information returns is accounted for. See the IRS transcripts guide for practitioners for the workflow to access wage and income transcripts through the Transcript Delivery System.
The June 2026 revision added an income fluctuation disclosure field. If the client's income varies significantly from month to month (seasonal employment, commissioned sales, gig economy income), the practitioner must note this in the disclosure field and document the basis for the monthly income figure used. For clients with highly variable income, using a 12-month average with documentation of each month's income is the defensible approach; verify the current IRS guidance on income fluctuation disclosure in IRM 5.15.1 at IRS.gov.
Monthly living expenses
The living expenses section is where the IRS National Standards and Local Standards are applied. Each expense category is compared against the applicable standard for the taxpayer's household size and geographic location. The IRS will allow the lesser of the actual expense or the applicable standard for most categories, without requiring documentation, as long as the claimed amount does not exceed the standard. Expenses above the applicable standard require documentation and a showing that the above-standard amount is necessary and not discretionary.
Monthly disposable income, which feeds into the RCP future-income calculation, is gross monthly income less IRS-allowed monthly expenses. Overstating expenses reduces the calculated disposable income, which reduces the RCP, which lowers the minimum acceptable offer amount. This is the arithmetic reason that the expense section receives the most IRS scrutiny.
Assets: bank accounts, real property, vehicles, and other
The assets section requires disclosure of every asset the taxpayer owns or has an interest in. Bank accounts are documented with the institution name, account number, and current balance, but the IRS requires a three-month average balance rather than the balance on any single day. Real property is documented with the address, current market value, any outstanding mortgage balance, and the resulting equity. Vehicles require make, model, year, current market value, outstanding loan balance, and equity. Other assets include life insurance cash value, retirement accounts, stocks, bonds, business interests, and any other property with realizable value.
Nothing is to be left blank. If the taxpayer has no interest in a particular asset category, the practitioner enters zero. A blank field reads as an incomplete form. An IRS reviewer will not assume the blank means zero; they will assume the section was skipped, and they will request a completed form.
Available credit
The available credit section asks for credit cards, home equity lines of credit, and other borrowing capacity. The IRS's position is that available credit is a potential source of payment that should be evaluated as part of the RCP analysis. A taxpayer with a significant unused home equity line of credit or substantial credit card capacity may have the ability to pay the liability through borrowing, and the IRS will consider this in the collectibility analysis. Practitioners should not omit available credit lines or underreport credit limits. The IRS has access to credit inquiry data and can identify undisclosed credit resources.
Equity calculation
The OIC version of Form 433-A includes a section where the practitioner calculates the net equity in each asset category: current value less any secured debt, then adjusted by the applicable quick-sale factor or equity reduction (for retirement accounts). This section ties directly to the RCP asset component. The accuracy of the equity calculation depends on accurate asset values and accurate debt balances. Both should be documented with current statements or appraisal information, not estimates.
IRS National Standards and Local Standards: Allowable Living Expense Analysis
ALWAYS USE CURRENT IRS STANDARDS AT TIME OF SUBMISSION
National Standards and Local Standards change periodically. Always use the current amounts published at IRS.gov at the time of submission. This guide does not state specific dollar figures for any standard: those figures are subject to change and must be pulled directly from the IRS Collection Financial Standards page (IRS.gov/businesses/small-businesses-self-employed/national-standards-food-clothing-and-other-items) at the time of each engagement. Using a prior period's standards on a current submission can produce an inaccurate expense analysis and an inaccurate RCP calculation. In addition, verify which National Standards period applies to your specific submission at IRS.gov, as standard publication schedules can be affected by delays in Bureau of Labor Statistics data releases.
The IRS updated the Collection Financial Standards on June 29, 2026. The allowable expense tables used to evaluate living expenses on Form 433-A and 433-B were revised as of that date. Always download the current standards directly from IRS.gov/businesses/small-businesses-self-employed/collection-financial-standards before completing the expense analysis; using outdated standards is a common error that can result in an overstated or understated expense allowance.
The IRS Allowable Living Expense standards are the mechanism by which the IRS controls what counts as a legitimate monthly expense for collection analysis purposes. The standards prevent a taxpayer from claiming arbitrarily high personal expenses to reduce disposable income and lower the RCP. They also give practitioners a defensible basis for claiming standard amounts without documentation, which reduces the evidentiary burden for expenses that fall within the permitted limits.
National Standards
National Standards apply to food, clothing and clothing services, housekeeping supplies, personal care products and services, and out-of-pocket health care expenses. These amounts are set at the national level and are the same regardless of where the taxpayer lives. They vary by household size. The IRS publishes these amounts in tables keyed to the number of people in the household. For any expense category covered by a National Standard, the IRS will allow the full standard amount without requiring documentation, up to the applicable standard limit. If the taxpayer's actual expense for a covered category is lower than the standard, the IRS uses the lower actual amount.
Look up the applicable National Standards for your client's household size at the IRS Collection Financial Standards page at IRS.gov each time you prepare a CIS. Do not use a saved copy from a prior engagement. The figures change, and the current period's figures are what the IRS will apply when it reviews the submission.
Local Standards
Local Standards apply to housing and utilities, and to transportation. Unlike National Standards, Local Standards are geographic: they are set by county and metropolitan statistical area, reflecting the significant variation in housing costs and transportation costs across the country. A taxpayer in a high-cost urban county has a higher allowable housing expense under the Local Standards than a taxpayer in a rural county, because the IRS recognizes that actual housing costs differ materially by location.
Transportation standards have two components: vehicle ownership costs (the monthly payment for a financed or leased vehicle, subject to the standard maximum) and vehicle operating costs (fuel, insurance, maintenance, and similar costs, set per vehicle by region). A taxpayer with one vehicle has one set of ownership and operating standards; a household with two vehicles can claim operating costs for each vehicle, but ownership costs are capped.
Look up Local Standards using the client's county of residence at the IRS Collection Financial Standards page. The IRS publishes Local Standards tables organized by state and county. Confirm the correct county and confirm the current standard amounts. In high-cost markets, the Local Standards for housing can be substantially lower than the client's actual housing cost, which creates an above-standards argument that requires documentation and is discussed in the next section.
Above-Standards Expenses: When the IRS Will Allow More Than the Standard Amount
The National and Local Standards represent the default allowable expense for each category. They are not hard ceilings. The IRS will allow expenses above the applicable standard when the taxpayer can demonstrate that the above-standard expense is necessary and not discretionary, and when the expense is documented. The operative phrase in the IRS framework is "necessary for the production of income or for the health and welfare of the taxpayer or the taxpayer's family."
Claiming above-standard expenses without documentation is a rejection trigger. The documentation does not need to be elaborate, but it must exist. For each above-standard expense, the practitioner should have a specific, non-speculative factual basis and the documentation to support it.
Common above-standards scenarios and the required documentation
Housing above the Local Standard
A taxpayer in a high-cost market may have a mortgage payment or rent that exceeds the applicable Local Standard for housing and utilities. To claim the above-standard amount, the practitioner submits the current mortgage statement or lease agreement showing the actual payment, documentation that the taxpayer cannot realistically relocate to less expensive housing (for example, the taxpayer's employment requires proximity to a specific location, or the mortgage is underwater making a sale impractical), and a written explanation of why the above-standard amount is necessary rather than discretionary. The IRS reviewer is applying a reasonableness test. A taxpayer with a $5,000 monthly mortgage payment in a market where the standard allows $2,500 will need a more developed argument than one with a $2,600 payment on a $2,500 standard.
Out-of-pocket health care above the National Standard
A taxpayer with a documented medical condition requiring ongoing treatment, prescription medications, or specialized care may have out-of-pocket health care expenses that exceed the applicable National Standard. Documentation includes physician statements, pharmacy records, explanation of benefits statements showing the taxpayer's portion after insurance, and documentation of any ongoing treatment protocols. The IRS will allow actual, documented, recurring medical expenses that exceed the standard when the condition and the expense are substantiated. Speculative future medical expenses are not allowable without a current medical basis.
Transportation above the Local Standard
Vehicle ownership costs above the Local Standard can arise when the taxpayer has an older vehicle with high repair costs or a vehicle whose value is below the standard but whose operating costs are above the standard due to age or condition. Documentation for above-standard transportation includes current repair invoices, vehicle maintenance records, and an explanation of why replacement of the vehicle is not a realistic option. The IRS approach is to evaluate whether the above-standard expense is a genuine cost of maintaining a functioning vehicle rather than a discretionary choice to drive a vehicle more expensive than the standard covers.
How to present the above-standards argument in the CIS
The CIS itself has limited space for narrative explanation. For above-standard expense arguments, practitioners typically attach a separate written explanation as part of the documentation package. The explanation should: state the specific expense category and the actual amount claimed, state the applicable standard amount and the amount by which the actual expense exceeds it, identify the factual basis for the above-standard need (the medical condition, the employment requirement, the housing market constraint), and reference the supporting documents attached. A reviewer who can follow the argument from the CIS to the explanation to the documentation will process the claim more efficiently than one who has to reconstruct the argument from scattered materials.
Assets and Equity Analysis: How the IRS Values What a Taxpayer Owns
The equity in assets is the first component of the RCP calculation. The IRS does not use full market value for most assets. It applies a discount that reflects what could realistically be recovered in a forced or expedited sale. Practitioners must understand how the IRS values each asset category so that the equity section of the CIS accurately reflects the IRS's calculation methodology, not the taxpayer's preferred valuation.
Bank account balances: the three-month lookback standard
The IRS does not use the balance in a bank account on the date the CIS is submitted. It uses the average balance over the preceding three months. This prevents taxpayers from artificially reducing the apparent balance by timing the submission after spending down the account. Practitioners calculate the three-month average balance from the account statements (beginning balance plus ending balance for each of three months, divided by six, or an equivalent calculation using monthly average balances depending on the statement format). The three-month bank statements must be submitted as supporting documentation for the CIS. Reporting a current balance that is lower than the three-month average, or omitting accounts entirely, is among the most common and most detectable forms of financial disclosure error.
Vehicle equity
Vehicle equity is calculated as the current market value of the vehicle less any outstanding loan balance. Current market value for IRS purposes is typically established using a recognized automotive valuation guide (such as Kelley Blue Book or NADA), at the applicable trade-in or private-party value. Practitioners should document the source of the valuation in the file.
For OIC purposes, the IRS applies a quick-sale discount to vehicle value, reflecting the difference between what a vehicle would bring in a private sale versus what would be recovered in an IRS levy and sale. Verify the current IRS quick-sale value policy in the current OIC guidelines at IRS.gov before applying any specific percentage to a client's vehicle equity: this methodology is set by IRM guidance that can be updated.
Real property: the 80 percent quick-sale value
For real property, the IRS historically applies a quick-sale value of 80 percent of fair market value in OIC equity calculations. This discount reflects the cost and time required to liquidate real property under forced sale conditions, rather than in an orderly market transaction. The equity available to satisfy the liability is therefore calculated as (fair market value times 80 percent) less the outstanding mortgage balance and any senior liens. Verify the current IRS quick-sale value policy in the current OIC guidelines at IRS.gov before applying any specific percentage to a client's property: the 80 percent figure reflects current IRS policy as stated in IRM guidance but is subject to revision.
Fair market value for real property should be documented with a current appraisal or a comparable sales analysis. In active markets, property values change quickly, and an appraisal more than six months old may not accurately reflect current value. The IRS can challenge a property value that it believes is stale or understated, and will use its own assessment data as a cross-check.
Retirement accounts
Retirement accounts are an asset for IRS equity purposes. The IRS does not exclude retirement accounts from the RCP calculation simply because they are tax-advantaged or subject to early withdrawal penalties. For OIC purposes, the IRS applies a reduction to retirement account balances to reflect the taxes and penalties that would be incurred on early withdrawal. The reduction applied is typically 30 percent of the account balance, representing the approximate combined effect of income tax and the 10 percent early withdrawal penalty for pre-59-and-a-half distributions. Verify current IRS retirement equity calculation guidance at IRS.gov before applying this methodology: the IRS's approach to retirement account equity in the RCP calculation can be updated through IRM guidance, and the applicable reduction may vary based on the type of account and the taxpayer's marginal tax rate.
The current balance in retirement accounts should be documented with the most recent account statement. Practitioners should confirm that the statement is current: a year-end statement from January does not accurately reflect mid-year market values.
The Documentation Package: What the IRS Requires Alongside Form 433-A
Form 433-A is not a self-contained submission. Every material figure on the form requires supporting documentation. The IRS will request whatever is missing, but a submission package that arrives incomplete creates processing delays and signals a disorganized case file. For an OIC submission where timing matters (the CSED is tolled while the offer is under review, but the clock ticks until the IRS confirms receipt of a complete package), arriving complete and organized on day one is a meaningful practical advantage.
Standard documentation requirements
- Bank statements: Three months of complete statements for every bank account, savings account, money market account, and certificate of deposit. "Complete" means every page of every statement, including pages that show only fees or zero transactions. The IRS reviewer confirms that the statements cover three consecutive months for each account and that the three-month average balance is consistent with the amount reported on the CIS. Missing statement pages or gaps in months will result in a request for the complete statements.
- Pay stubs: The two most recent pay stubs for each employer from which the taxpayer receives wages. Pay stubs document gross pay, withholdings, and net pay for comparison against the monthly income figures on the CIS. If the taxpayer receives irregular pay (commissions, bonuses, or variable hours), additional stubs may be needed to document an accurate monthly average.
- Mortgage statements: The most recent mortgage statement for each real property showing the outstanding balance, monthly payment, property address, and lender. For properties with equity, a current appraisal or documented comparable sales analysis to support the stated fair market value. For properties with significant equity, the IRS may request an independent appraisal.
- Vehicle loan balances: The most recent statement from each vehicle financing lender showing the current payoff balance, monthly payment, and vehicle description. For vehicles owned free and clear, documentation of current market value from an automotive valuation guide.
- Title documents: Vehicle titles and real property deeds, or copies of same, particularly where the IRS is evaluating whether a lien has been filed against the property. Title documentation confirms ownership and any existing encumbrances that are senior to the IRS's position.
- Business financial statements: For self-employed individuals and sole proprietors, the two most recent years of business tax returns (Schedule C and any related forms) and a current profit and loss statement. The profit and loss statement should be current to within 30 to 60 days of the CIS submission.
- Retirement account statements: The most recent statement for each retirement account showing the current account balance. If a recent statement is not available, request one from the account custodian before submitting.
- Life insurance cash value: Documentation from the insurance carrier of the current cash surrender value for any whole or universal life insurance policies. Term life insurance has no cash value and is not an asset for CIS purposes.
Above-standard expense documentation
For any expense claimed above the applicable National or Local Standard, the documentation is the argument. Invoices, lease agreements, medical records, pharmacy statements, and employer letters establishing travel requirements are the types of evidence that support above-standard claims. Organize above-standard documentation separately and label it clearly with the expense category and the relevant section of the CIS.
Practitioner organization checklist before submission
Before submitting the CIS package, the practitioner should verify each of the following:
- Every section of the form is completed; no section is left blank.
- All income sources from transcript data are accounted for on the form.
- Bank account balances reflect three-month averages, not current balances.
- Three months of complete bank statements are included for each account.
- Expense amounts at or below the applicable National and Local Standards are documented in the practitioner's file, even if supporting documentation is not required for the submission.
- Each above-standard expense has a written explanation and supporting documentation attached.
- The form is signed and dated by the taxpayer.
- The form version matches the current revision published at IRS.gov.
- For OIC submissions, the Form 433-A OIC version is used, not the standard Form 433-A.
Common IRS Rejection and Return Triggers for Form 433-A
Most collection resolution rejections and returns are preventable. The following are the issues that practitioners encounter most often. None of them require extraordinary effort to avoid; they require a complete pre-submission review against a consistent checklist.
Missing or blank sections
A blank section on Form 433-A signals an incomplete form to the IRS reviewer. If the taxpayer has no interest in a particular asset category, the correct entry is zero, not blank. If the taxpayer does not own a vehicle, enter zero in the vehicle section. If the taxpayer has no life insurance cash value, enter zero. The IRS reviewer cannot distinguish between a zero-balance situation and a skipped section unless you make it explicit. A form with blank sections will be returned for completion, adding weeks to the timeline.
Unsigned form
Form 433-A requires the taxpayer's signature under penalties of perjury. An unsigned form is invalid. For a practitioner filing on behalf of a married couple, both spouses may need to sign depending on the circumstances. Confirm signature requirements against the current form instructions at IRS.gov. Sending a complete, accurate financial disclosure on an unsigned form will result in return without processing and a delay.
Wrong form version
Submitting the standard Form 433-A for an OIC case, or submitting a prior-revision version of Form 433-A OIC, results in return without processing. The IRS requires the current revision of the correct form. Verify the current revision number and download the form fresh from IRS.gov before each submission. Older versions of the form saved in practice management software, document management systems, or prior client files are the most common source of outdated form versions.
Bank balances that do not match statements
The IRS cross-references bank balances reported on Form 433-A against the supporting bank statements. If the balance on the form does not match the three-month average calculated from the statements, the reviewer will flag the discrepancy. Rounding errors and arithmetic mistakes are correctable, but a systematic pattern of reported balances being lower than the statement averages is a red flag. Calculate the three-month average balance carefully for each account and confirm that the figure on the form matches the calculation from the statements before submission.
Expense claims above standards without documentation
Claiming an expense above the applicable National or Local Standard without attaching supporting documentation invites either rejection of the above-standard portion of the expense (which increases calculated disposable income and raises the RCP) or an outright return of the submission for documentation. If the above-standard claim is necessary to the resolution strategy, invest the time to assemble the documentation before submitting. An above-standard housing claim with three months of mortgage statements and an employment letter explaining why the client cannot relocate is a supportable argument. The same claim without documentation is not.
Omitting a spouse's income or assets
For married taxpayers, the IRS requires the non-filing spouse's financial information on Form 433-A even when only one spouse has the tax liability. Community property states present additional complexity: the IRS may have a right to collect from community assets regardless of which spouse incurred the liability. Omitting a spouse's income from the CIS produces an understated income figure that does not survive IRS verification. Pull transcript data for both spouses before completing the form.
Income figures inconsistent with transcript data
The IRS will pull wage and income transcripts for the taxpayer as part of the review process. If the monthly income figure on Form 433-A is inconsistent with the annualized income shown on the transcripts, the reviewer will request an explanation. Seasonal income, recent job changes, or multiple employers can create apparent discrepancies that have legitimate explanations, but those explanations must accompany the submission rather than being reactive. See the IRS transcripts guide for practitioners for how to pull and read wage and income transcripts before completing the income section.
Form 433-B: Collection Information Statement for Businesses
Form 433-B serves the same foundational purpose as Form 433-A but for business entity taxpayers. The structure parallels the individual form, but the content reflects the distinct financial picture of a business: operating assets, accounts receivable, business income and expenses, outstanding liabilities, and the entity's ability to pay from ongoing operations. Partnerships, corporations, and LLCs taxed as entities use Form 433-B. Sole proprietors, as noted above, use Form 433-A and report business income and expenses within the individual form.
Key differences from Form 433-A
- Business asset valuation: Form 433-B requires disclosure of business assets including cash on hand and in bank accounts, accounts receivable, notes receivable, inventory, equipment, and any real property owned by the business. Business equipment is valued at liquidation value, not book value, reflecting what could be recovered in a forced sale. The IRS expects the practitioner to know the difference between the depreciated tax value of equipment on the balance sheet and its fair market liquidation value, which may be higher or lower depending on the nature of the equipment and current market conditions.
- Digital assets: The June 2026 revision to Form 433-B added digital assets as a separate asset category, distinct from cash and bank accounts. Practitioners must report all digital assets (cryptocurrency, NFTs, digital tokens) at current fair market value, with the exchange or wallet where they are held. If the client's digital assets are held across multiple exchanges or wallets, each must be listed separately. Fair market value is the current market price on the date the form is completed; verify current pricing through the exchange or a CoinMarketCap-equivalent source and document the source used.
- Accounts receivable: Outstanding accounts receivable are an asset for IRS purposes. The IRS evaluates whether receivables are current and collectible or aged and uncollectible. A business that carries significant accounts receivable that are actively being collected has a different collection picture than one with the same nominal receivable balance that is largely uncollectible. Practitioners should document the aging of receivables (current, 30, 60, and 90 days or more) to give the IRS an accurate view of realizable receivable value rather than the gross balance.
- Monthly business income and expenses: Form 433-B requires monthly gross income and ordinary business expenses, arriving at net monthly income available from business operations. Unlike individual expenses, business expenses are not constrained by the IRS Allowable Living Expense standards. Ordinary and necessary business expenses under IRC Section 162 are the applicable standard for business deductions. The IRS is, however, skeptical of expense claims that have not been consistently reported on the business's tax returns, and will compare the Form 433-B expense figures against the business returns on file.
- Business viability analysis: For an OIC or installment agreement involving a business entity, the IRS will evaluate whether the business is viable going forward, meaning whether it produces enough net income to fund an installment agreement or whether it is a declining operation where collection through the OIC program produces a better outcome than waiting for full collection. A business with no reasonable prospect of sustained profitability has a different RCP profile than one with stable revenues. Practitioners should be prepared to make a clear factual argument about the business's ongoing viability as part of the resolution analysis.
When both Form 433-A and Form 433-B are required
When an individual owns a business and both the individual and the business have tax liabilities, the practitioner must complete both forms. This is the most common scenario in trust fund recovery penalty cases. The IRS has assessed or may assess the individual officer or owner for the unpaid employment taxes of the business under IRC Section 6672, making the individual personally liable for the trust fund portion of the business's payroll tax debt. The practitioner needs to capture the full financial picture of both the individual and the business to structure a resolution that addresses both liability streams.
See the federal tax lien guide for tax preparers for how a lien filed against an individual owner interacts with a business liability, and what lien withdrawal and subordination options may be available in resolution proceedings.
Connecting the CIS to the Resolution Strategy: The Form Is the Foundation, Not a Standalone Document
Form 433-A is not an end in itself. It is the input to the resolution analysis. Every collection resolution tool available to a credentialed practitioner, the OIC, the installment agreement, the collection alternative at a CDP hearing, runs through the financial picture documented on the CIS. A practitioner who completes Form 433-A without simultaneously working through the RCP calculation is filling out paperwork. A practitioner who completes it as the analytical foundation of a resolution strategy is doing the work.
Form 433-A and the OIC RCP calculation
The Reasonable Collection Potential for a Doubt as to Collectibility OIC is calculated directly from the figures on Form 433-A OIC. The two RCP components are: net realizable equity in assets (quick-sale value of all assets less secured debts, subject to applicable equity reductions) and future income (monthly disposable income after National and Local Standard allowable expenses, multiplied by 12 for a lump-sum cash offer paid within five months of acceptance, or 24 for a periodic payment offer). The offer amount must equal or exceed the RCP for the IRS to consider acceptance.
Before completing Form 433-A OIC, the practitioner should run a preliminary RCP calculation to test whether an OIC is viable for this client. If the preliminary RCP exceeds the outstanding balance, there is no mathematical basis for a Doubt as to Collectibility offer. At that point, the appropriate resolution path is an installment agreement or, in limited circumstances, a partial-pay installment agreement. See the IRS OIC preparer guide for the pre-qualification analysis and when not to file an OIC.
Form 433-A and the installment agreement payment floor
For installment agreements that require financial review, the IRS uses the CIS to establish the minimum acceptable monthly payment. The payment floor is the taxpayer's monthly disposable income after IRS-allowed living expenses, calculated from the National and Local Standards applied to the taxpayer's household. The IRS will not approve a payment below that floor in a financially reviewed IA. If the calculated disposable income is higher than what the client told you they could afford, the CIS analysis tells you before the IRS does, allowing the practitioner to either document above-standard expenses that reduce the disposable income figure or adjust the client's expectations about the monthly payment. See the installment agreement preparer guide for payment calculation methodology and IA type eligibility thresholds.
Form 433-A and CDP hearing financial documentation
When a taxpayer proposes a collection alternative at a CDP hearing, the Settlement Officer evaluating the proposal will apply the same financial analysis the IRS would apply if the alternative were submitted outside the hearing context. A proposed OIC at a CDP hearing requires Form 433-A OIC. A proposed installment agreement at a CDP hearing requires Form 433-A financial analysis to support the proposed payment. Arriving at a CDP hearing with an incomplete or unsubmitted CIS effectively forecloses the collection alternative argument. See the CDP hearing guide for tax preparers for the hearing timeline, the collection alternatives available, and how to prepare the alternative proposal for submission.
Related guides in the collection resolution cluster
The CIS is the foundation; these guides cover the resolution tools built on top of it:
- IRS Offer in Compromise preparer guide: OIC grounds, RCP calculation, Form 656 filing, and when not to file
- IRS installment agreement preparer guide: IA types, balance thresholds, payment calculation, and partial-pay IA
- CDP hearing guide for tax preparers: the 30-day window, collection alternatives at the hearing, and representation rights
- Federal tax lien guide for tax preparers: lien filing, withdrawal, subordination, and discharge
- IRS penalty abatement guide for tax preparers: first-time abatement, reasonable cause, and the abatement request workflow
- IRS representation rights comparison guide: which credentials authorize collection representation and when to refer
- Form 2848 Power of Attorney guide for tax preparers: completing Form 2848, CAF submission, and authorization scope for collection matters
- IRC 6334 property exempt from IRS levy: the 11 exempt property categories, the wage levy minimum exemption formula under 6334(d), and the pension necessary-for-support standard the CIS financial analysis intersects
Regulated Claims and Verification Requirements
The following items in this guide are subject to IRS policy changes and must be verified at IRS.gov before relying on them in client engagements: (1) National Standards and Local Standards figures: not stated in this guide; verify current amounts at IRS.gov/businesses/small-businesses-self-employed/national-standards-food-clothing-and-other-items at the time of each submission. (2) Form 433-A OIC current revision: referenced as Rev. 4-2026 as of publication date; verify the current revision at IRS.gov before every submission, as using an outdated revision causes return without processing. (3) Quick-sale value for real property: referenced as 80 percent of FMV as a matter of current IRS OIC policy; verify the current IRS quick-sale value policy in the current OIC guidelines at IRS.gov. (4) Retirement account equity reduction: referenced as approximately 30 percent to reflect early withdrawal taxes and penalty; verify current IRS retirement equity calculation guidance at IRS.gov, as this methodology is set by IRM guidance subject to revision. (5) National Standards period: as industry context, the April 2025 National Standards were reported to be in effect through June 2026 due to BLS data delays; verify which National Standards period applies to your submission at IRS.gov. (6) RCP multiplier: 12 months for lump-sum offers, 24 months for periodic payment offers; current IRS policy under IRM guidance, subject to revision. This guide is informational and does not constitute legal or tax advice.
Frequently Asked Questions
What is the difference between Form 433-A and Form 433-A OIC?
Form 433-A is the standard Collection Information Statement for individual taxpayers. It is used in Revenue Officer cases, financially reviewed installment agreement requests, and CDP hearing collection alternative proposals. Form 433-A OIC is a separate, longer version required specifically for Offer in Compromise submissions. The OIC version includes additional sections for the equity analysis and Reasonable Collection Potential calculation that the standard version does not contain. Submitting the standard Form 433-A for an OIC case is a common rejection trigger that results in the offer being returned without processing. Verify the current form versions and revision numbers at IRS.gov before filing.
What are IRS National Standards and Local Standards, and where do I find current amounts?
National Standards are IRS-published allowable monthly expense amounts for food, clothing, housekeeping supplies, personal care products, and out-of-pocket health care costs. Local Standards cover housing and utilities, and transportation costs including vehicle ownership and operating expenses, and vary by county and metropolitan area. The IRS uses these standards to evaluate living expense claims on Form 433-A; expenses at or below the standard are generally allowed without documentation. National Standards and Local Standards change periodically. Always use the current amounts published at IRS.gov at the time of each submission. The IRS Collection Financial Standards page is the authoritative source. Do not rely on prior-year figures or saved copies from earlier engagements.
How does the IRS calculate vehicle equity on Form 433-A?
The IRS calculates vehicle equity as the current market value of the vehicle less any outstanding loan balance. For OIC purposes, the IRS applies a quick-sale value discount to the market value rather than using full retail value, reflecting what could realistically be recovered in a forced sale. Current market value is typically established using a recognized automotive valuation guide. Verify the current IRS quick-sale value methodology in the current OIC guidelines at IRS.gov before applying it to a client's case. Document the valuation source in the file alongside the supporting loan balance statement.
What bank statements does the IRS require with Form 433-A?
The IRS standard documentation requirement for bank accounts is three months of complete statements for each account. The IRS uses a three-month average balance rather than the balance on a single date to reduce the impact of timing fluctuations. Practitioners must calculate and report the average balance from the three-month lookback period, not the current balance on the submission date. All accounts must be disclosed: checking, savings, money market, and certificates of deposit. Omitting an account or reporting a single-day balance instead of the three-month average are both detectable errors that will draw scrutiny from the reviewer.
When is Form 433-B required in addition to Form 433-A?
Form 433-B is required when the taxpayer is a business entity: a partnership, corporation, or LLC taxed as an entity. When an individual client owns a business that also owes taxes, both Form 433-A and Form 433-B may be required. This situation is most common in trust fund recovery penalty cases where the IRS has assessed or may assess the individual owner for the business's unpaid employment taxes under IRC Section 6672. Sole proprietors report business income and expenses on Form 433-A rather than Form 433-B, because a sole proprietor and the business are the same legal taxpayer for IRS purposes.