Understanding IRS Collection Standards in St. Mary's County
Navigating IRS enforced collection actions in St. Mary's County, Maryland, requires a precise understanding of the IRS Collection Financial Standards. When the IRS evaluates a taxpayer's ability to pay, typically via Form 433-A, Collection Information Statement, they calculate disposable income by subtracting allowable living expenses from gross income. These expenses are determined by a combination of National and Local Standards, derived from comprehensive data by the Bureau of Labor Statistics and the U.S. Census Bureau. For instance, a single individual in St. Mary's County is allowed $812 monthly for food, clothing, and other necessities. While specific IRS local housing standards for this area are not published, actual necessary housing costs are considered. The objective is to determine if enforcing collection would create an 'economic hardship,' a condition that, under Internal Revenue Code (IRC) §6343(a)(1)(D), may lead to a levy release or the placement of an account into Currently Not Collectible (CNC) status.
St. Mary's County Housing & Utilities Allowance vs. HUD Fair Market Rent
For St. Mary's County, MD HUD Metro FMR Area, the IRS Collection Financial Standards do not provide a pre-set local housing and utilities allowance. In such cases, taxpayers must substantiate their actual, necessary housing and utility expenses. This is where data from the U.S. Department of Housing and Urban Development (HUD) becomes crucial. For FY2025, the HUD Fair Market Rent (FMR) for a 2-bedroom residence in St. Mary's County is $1830.0. If a taxpayer's actual housing costs align with or are below this FMR, it provides a strong basis for their necessary expense claim. When actual, reasonable expenses exceed the general IRS standards (or, in this case, a reasonable benchmark like FMR), Internal Revenue Manual (IRM) 5.15.1.10 allows for a deviation from the standard amounts. While regional Shelter CPI data for this specific region is not available from the Bureau of Labor Statistics, the HUD FMR provides a robust local economic indicator for housing costs.
Food, Healthcare & Transportation Allowances
Beyond housing, the IRS allows for specific National and Local Standards for essential living expenses. For food, clothing, and other necessities, the National Standards, based on the Bureau of Labor Statistics Consumer Expenditure Survey, provide allowances ranging from $812 for a single person to $1983 for a family of four. Healthcare expenses, derived from the Medical Expenditure Panel Survey, allow $75 per person monthly for those under 65 and $153 for those 65 and over. Transportation allowances for St. Mary's County are also specific: owning one car permits an allowance of $588 for ownership costs and $270 for operating costs, totaling $858 per month. These figures, rooted in BLS data and American Automobile Association operating costs, are critical for accurately calculating a taxpayer's ability to pay and establishing an allowable expense budget.
Qualifying for Currently Not Collectible (CNC) Status in Maryland
Achieving Currently Not Collectible (CNC) status in Maryland involves demonstrating to the IRS that, after accounting for allowable living expenses, you have no disposable income to apply to your tax debt. The process begins with filing an accurate Form 433-A, Collection Information Statement, detailing your income, assets, and expenses. For a single filer in St. Mary's County, the calculation would incorporate their actual necessary housing expenses (e.g., $1830.0 for a 2-bedroom FMR benchmark), combined with National Standard allowances such as $812 for food, clothing, and other items, $75 for healthcare (if under 65), and the Local Transportation Standard of $858 for one car. If total allowable expenses exceed net income, the IRS, following IRM 5.16.1 procedures, may place the account into CNC status. This status prevents enforced collection actions, including levies under IRC §6331, and may lead to the release of an existing levy under IRC §6343. Importantly, CNC status does not extend the Collection Statute Expiration Date (CSED) under IRC §6502, which typically limits the IRS to 10 years for collection.