Currently not collectable -doubt as to liability


My client has 2 years that she is being assessed for. Both were because she missed reporting income (she has reasonable cause). I recomputed both years and agree with year 1 but am about $6k less then the assessed tax. Client does not have all of the notices, so I don’t have the details of the IRS calculation, I just see a lump sum assessed. My question is, should this be CNC- doubt as to liability? and if so, how do I do this for a partial CNC?


This could be an OIC (not CNC) on Doubt as to Liability to reopen the assessment.

  1. Get IRP (income reported) for the years involved
  2. Call PPL Practitioner Hotline and see if you can get the contact info for the Under Reporter Unit so that you can get a copy of the CP2000 that generated the liabilities.
  3. you have the option of an Audit Reconsideration (my personal preference) or an OIC DATLiability.


Thank you Marc.

That is exactly what I needed to know. Your reply is very helpful.

Jodi Riggins
Advanced Tax and Financial Solutions