Understanding IRS Collection Standards in Flint, MI MSA
For taxpayers in the Flint, Michigan MSA facing IRS collection actions, understanding the IRS Collection Financial Standards is crucial for navigating potential wage levies (Form 668-W) or bank levies (Form 668-A). The IRS uses these standards, outlined on Form 433-A (Collection Information Statement for Wage Earners and Self-Employed Individuals), to determine a taxpayer's reasonable living expenses and, consequently, their disposable income. These standards encompass National Standards for categories like food, clothing, and other necessities, and Local Standards for housing, utilities, and transportation. For a single person in Flint, the National Standard for Food, Clothing, and Other is $812 per month. Notably, the IRS does not provide a specific Local Standard for Housing and Utilities for the Flint, MI MSA, requiring taxpayers to justify actual expenses. If your allowable expenses exceed your income, the IRS may determine that collection would create an economic hardship, as defined under IRC §6343(a)(1)(D), potentially leading to a levy release or placement into Currently Not Collectible (CNC) status. This critical data is derived from authoritative sources like IRS.gov, Bureau of Labor Statistics (BLS), and the US Census Bureau.
Flint, MI MSA Housing & Utilities Allowance vs. HUD Fair Market Rent
Taxpayers in the Flint, MI MSA face a unique challenge regarding housing and utilities, as the IRS Collection Financial Standards do not list a specific Local Standard for this area for 1, 2, 3, 4, or 5+ person households. This means the IRS will evaluate your actual housing and utility expenses for reasonableness. In contrast, the US Department of Housing and Urban Development (HUD) provides Fair Market Rent (FMR) data for the Flint, MI MSA, indicating that a 2-bedroom unit has an FMR of $1210.0 per month for FY2025. If your actual, necessary housing expenses exceed what the IRS might typically allow in other regions, you can argue for a deviation from standard allowances, as permitted by Internal Revenue Manual (IRM) 5.15.1.10. Documenting your rent, mortgage, and utility bills is essential to substantiate your claim. Given that no regional shelter Consumer Price Index (CPI) data is available for the Flint, MI MSA from the Bureau of Labor Statistics, justifying your actual housing costs through comparison with HUD FMRs becomes even more critical to demonstrate a legitimate hardship.
Food, Healthcare & Transportation Allowances
Beyond housing, the IRS allows for other essential living expenses. Under the National Standards, a single person in Flint, MI MSA is allowed $812 monthly for Food, Clothing, and Other expenses. This amount is based on Bureau of Labor Statistics Consumer Expenditure Survey data and breaks down to $449 for food, $44 for housekeeping supplies, $99 for apparel and services, $45 for personal care products and services, and $175 for miscellaneous items. For a family of four, this allowance rises to $1983. Healthcare is covered by National Standards for Out-of-Pocket Healthcare, allowing $75 per person per month for those under 65 and $153 for those 65 and over, derived from the Medical Expenditure Panel Survey. For transportation in the Flint, MI MSA, Local Standards allow for significant costs: $588 per month for the ownership of one car, plus an additional $270 per month for operating costs in this specific region. This totals $858 per month for one car, based on Bureau of Labor Statistics data and American Automobile Association (AAA) operating cost analyses. These allowances are vital for calculating your ability to pay your tax debt.
Qualifying for Currently Not Collectible (CNC) Status in Michigan
Achieving Currently Not Collectible (CNC) status can provide temporary relief from IRS enforced collection actions like wage or bank levies in Michigan. To qualify, you must demonstrate to the IRS that your income is insufficient to cover your necessary living expenses, leaving no disposable income to pay your tax debt. This process begins by submitting a comprehensive Form 433-A, detailing your income, assets, and expenses. For a single filer in the Flint, MI MSA, your total allowable monthly expenses might include a justified housing expense (e.g., the HUD FMR for a 2BR at $1210.0), plus $812 for Food, Clothing, and Other, $75 for healthcare (under 65), and $858 for one-car transportation. If your total income does not exceed the sum of these essential expenses, you may qualify for CNC. The IRS outlines CNC procedures in IRM 5.16.1, emphasizing that this status is a temporary measure. While in CNC status, the IRS will generally cease collection actions, including releasing levies under IRC §6343. Importantly, being in CNC status does not extend the Collection Statute Expiration Date (CSED), which, under IRC §6502, is typically 10 years from the date of assessment.