Form 433-A or Form 433-F: Which One You Will Be Asked For

It is easy to end up with a Form 433-A, a Form 433-F, and a Form 433-A (OIC) on the kitchen table, all half filled out, because different people at the IRS asked for different things. That is enough to make anyone want to quit.

Here is the sorting rule. Which collection information statement you complete depends on which part of the IRS has your case and what you are asking for. The financial analysis underneath them is the same, governed by the Financial Analysis Handbook in IRM 5.15.1.

The family of forms

IRM 5.15.1.2 lists three collection information statements:

• Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals.
• Form 433-B, Collection Information Statement for Businesses.
• Form 433-F, Collection Information Statement, used by the Automated Collection System and the campuses for individuals.

An offer in compromise uses its own version, Form 433-A (OIC), which comes in the offer package. This site focuses on Forms 433-A and 433-F because those are the forms behind most hardship and CNC requests.

Who asks for Form 433-A

Revenue officers in Field Collection generally work from Form 433-A. If a revenue officer has been assigned to your case, you have probably received an appointment letter and a blank 433-A. The field procedures in IRM 5.16.1.2.9 for hardship cases say to schedule an appointment, "Secure a Collection Information Statement (CIS)," and that "The CIS must support the CNC recommendation to report the account as hardship."

Self-employed individuals with a sole proprietorship also tend to land on Form 433-A, because Sections 6 and 7 capture business income and expenses in detail.

Who asks for Form 433-F

ACS and campus collection functions use Form 433-F or take the same information over the phone. Revenue officers may also use it in two limited cases under IRM 5.15.1.2:

• Trust Fund Recovery Penalty investigations when the individual is a wage earner and the potential penalty is less than $100,000.
• Self-employed and individual wage earners who owe individual liabilities only, with an aggregate balance of assessments under $250,000.

The hard rule: offers need the long form

IRM 5.15.1.2 states it directly: "Form 433-F cannot be used for Offer-in-Compromise cases." If you think an offer may be the better path, and for many permanent hardship cases it is, plan on Form 433-A (OIC). I compare those paths in CNC vs. installment agreement vs. offer.

Side by side

What does not change between them

The forms are different. The analysis is not.

• Both rely on the same Collection Financial Standards, the national and local allowances that define "reasonable" expenses.
• Both treat a business loss or rental loss as zero income, and both disregard depreciation because it is not a cash expense.
• Both disallow voluntary retirement contributions and most unsecured debt payments as necessary expenses, with narrow exceptions.
• Both are signed under penalties of perjury and can be verified against IRS records, bank statements and third-party information.

If you give the IRS a Form 433-F today and a revenue officer later asks for a Form 433-A, the numbers should match. An inconsistency between two statements is one of the fastest ways to lose credibility.

How old can a statement be?

IRM 5.15.1.2 says a statement submitted by a taxpayer "should reflect information no older than the prior six months." If the information becomes older than 12 months during the investigation, it should be updated. For CNC specifically, IRM 5.16.1.2 says the statement supporting the decision is considered current if it is less than twelve months old.

The practical lesson: do not dig out last year's financial statement and resubmit it. Prepare a fresh one with current numbers and current proof.

Married couples and joint balances

Both forms are built for households. Form 433-A asks for both spouses' employment, wages, pensions and Social Security on separate lines. Form 433-F asks for both spouses' employers and pay. If you owe jointly, both spouses sign. If only one spouse owes, the other spouse's income still shows up, because the IRS has to figure out what share of the household's shared expenses the liable spouse actually pays.

That allocation is one of the most technical parts of the analysis, and it works the same way on either form. I walk through it in shared household expenses.

When you get no form at all

Some small-balance hardship cases close without any financial statement. Both the field and campus procedures allow CNC exception processing when the balance is under a threshold and the taxpayer has a terminal illness or excessive medical bills, is incarcerated, lives only on Social Security, welfare or unemployment, or is unemployed with no income. See CNC exception processing for what that looks like.

Verification differs by unit, too

The form is not the only thing that changes with the unit. So does the level of checking. The field hardship procedures in IRM 5.16.1.2.9 scale verification to the balance. At lower balances a revenue officer may accept a statement that "appears reasonable." At higher balances the IRM calls for online locator research, review of recently filed returns, motor vehicle records, courthouse property records, and, for the largest balances, a full credit report. The exact dollar breakpoints are redacted in the public IRM, so do not let anyone tell you precisely where they fall.

Campus units work from a separate set of authority levels in IRM 5.19.13.2. For partial pay agreements and CNC, the tables call for verification of assets, income and expenses through internal sources, and paper substantiation when an amount looks unreasonable, or when claimed expenses exceed the standards and allowing them would produce a partial pay or hardship result.

Either way, assume your numbers will be compared against wage and income records, prior returns, and bank deposits. Prepare your statement with that comparison in mind.

Switching units midstream

Cases move. An account that starts in ACS can be assigned to a revenue officer, and a field case can be returned to the queue. When that happens, the new employee may ask for a different form. Do not treat that as a fresh start. IRM 5.15.1.4 says collection issues addressed during an investigation by field personnel in the preceding 12 months will not be re-examined unless there is convincing evidence that reinvestigation is absolutely necessary. If you already gave the IRS a complete, verified statement, point to it.

The flip side is that an earlier statement follows you. If the new numbers look very different from the old ones, have an explanation ready, in writing, with proof.

My practical advice

Start with Form 433-A even if you were asked for Form 433-F. The long form forces you to think through every asset and every income source, including the uncomfortable questions in Section 3. Once you have done that work, transferring the numbers to the short form takes twenty minutes, and you will not be surprised later.

The IRS does not care which form you like better. It cares whether the numbers are complete, current and true. Give it that, on whichever form it asks for.