Understanding IRS Collection Standards in Franklin County
When facing IRS collection actions in Franklin County, Tennessee, understanding the IRS Collection Financial Standards is crucial for determining your ability to pay. The IRS uses these standards, along with information from your submitted Form 433-A, Collection Information Statement, to calculate your disposable income. These standards include National Standards for categories like Food, Clothing, and Other, and Local Standards for Transportation. For a single individual in Franklin County, the monthly food allowance is $449, contributing to a total National Standard of $812. For a family of four, this rises to $1983. Importantly, while the IRS Collection Financial Standards provide specific allowances derived from US Census Bureau American Community Survey and Bureau of Labor Statistics data, Franklin County, TN does not have a specific housing and utilities allowance. In such cases, the IRS evaluates actual reasonable expenses. If your income, after accounting for these necessary living expenses, leaves little to no disposable income, you may qualify for economic hardship status under IRC §6343(a)(1)(D), potentially leading to a levy release or Currently Not Collectible (CNC) status.
Franklin County Housing & Utilities Allowance vs. HUD Fair Market Rent
A significant point for Franklin County, TN taxpayers is the absence of a designated IRS Local Standard for Housing and Utilities. The IRS Collection Financial Standards explicitly list 'N/A' for these allowances in Franklin County. This means the IRS will evaluate your actual, reasonable housing and utility expenses. To determine what constitutes a 'reasonable' expense, taxpayers can reference data such as the HUD FY2025 Fair Market Rent (FMR) for the area. For example, the HUD FMR for a 2-bedroom residence in Franklin County, TN is $930.0 per month. If your actual housing costs exceed this, or if you need to establish a reasonable allowance, presenting FMR data can be highly beneficial. Under IRM 5.15.1.10, taxpayers can request a deviation from the standard allowances if their actual necessary expenses are higher. Since specific regional Shelter CPI data is not available for this region from the Bureau of Labor Statistics, justifying actual expenses against HUD FMR becomes an even stronger argument to demonstrate financial hardship and prevent an aggressive IRS enforced collection action.
Food, Healthcare & Transportation Allowances
Beyond housing, the IRS provides specific allowances for essential living expenses. For food, clothing, and other necessities, National Standards apply uniformly across the U.S., based on the Bureau of Labor Statistics Consumer Expenditure Survey. For a single person, the monthly allowance is $812. This increases to $1478 for a two-person household, $1697 for three, and $1983 for a four-person household, with an additional $357 for each subsequent person. Healthcare is also covered by National Standards, derived from the Medical Expenditure Panel Survey. For individuals under 65, the monthly out-of-pocket healthcare allowance is $75 per person, while those 65 and over receive $153 per person. Regarding transportation, Franklin County, TN taxpayers are subject to IRS Local Standards. For one owned car, the allowance is $588 for ownership costs plus $270 for operating costs, totaling $858 per month. For two owned cars, the ownership allowance is $1176, plus the $270 operating cost per vehicle, totaling $1446. These figures are based on Bureau of Labor Statistics data and American Automobile Association operating costs, providing a clear framework for allowable expenses.
Qualifying for Currently Not Collectible (CNC) Status in Tennessee
Achieving Currently Not Collectible (CNC) status in Franklin County, Tennessee, is a critical relief option for taxpayers experiencing severe financial hardship. To qualify, you must demonstrate to the IRS that your income is insufficient to cover basic living expenses, leaving no funds available for tax payments. This is primarily established by submitting IRS Form 433-A, Collection Information Statement, detailing your assets, liabilities, income, and expenses. The IRS then compares your total income against your total allowable expenses, which include the National Standards (e.g., $812 for a single person's food, clothing, and other expenses) and Local Standards (e.g., $858 for one-car transportation in Franklin County). Since there's no specific housing allowance for Franklin County, your actual reasonable housing costs, such as the HUD FMR of $930.0 for a 2-bedroom residence, are considered. For a single filer, if their income after allowing for $930.0 for housing, $812 for food, $75 for healthcare (under 65), and $858 for transportation totals $2675, leaves them with no disposable income, CNC status is likely. If approved, the IRS will cease active collection efforts, including releasing any existing levies under IRC §6343. It's important to note that while CNC status halts collection, it does not stop interest and penalties from accruing, nor does it extend the Collection Statute Expiration Date (CSED) under IRC §6502, which typically limits the IRS to 10 years to collect the debt.