Key Takeaway
The IRS conducts financial analysis in four stages when evaluating a taxpayer’s ability to pay: (1) income verification, (2) asset valuation, (3) allowable expense analysis, and (4) ability-to-pay calculation. The short version is that the IRS reviews Form 433-F or 433-A disclosure against internal data sources (prior returns, third-party information returns, bank records if summoned), applies Collection Financial Standards for allowable expenses, values assets at quick-sale rates, and computes monthly disposable income. This analysis drives every collection resolution. Understanding how the IRS does the math — and where judgment is applied — is the difference between a sustainable resolution and an unsustainable one.1
Going through IRS financial review? A 15-minute consultation is free.
The IRS financial analysis drives IA monthly payments, PPIA calculations, OIC RCP, and CNC eligibility. The analysis is systematic but includes discretionary points where careful documentation produces better outcomes. This chapter walks through the four stages and the practical tips for each.
Our firm has navigated thousands of IRS financial analyses. For related framework, see Allowable Living Expenses. For collection framework, see 5 Strategies to Resolve Tax Debt.
The Four Stages of IRS Financial Analysis
Stage 1Income Verification
Stage 2Asset Valuation
Stage 3Expense Analysis
Stage 4Ability-to-Pay
| Stage | Focus | Documentation2 |
|---|---|---|
| Income Verification | All sources of income | Pay stubs, 1099s, bank records |
| Asset Valuation | Quick-sale value of assets | Appraisals, statements, titles |
| Expense Analysis | Lesser of actual or CFS | Bills, court orders, medical records |
| Ability-to-Pay | Net income minus allowable expenses | Summary calculation |
Quick Reference
Jump to the stage: income verification, asset valuation, expense analysis, or ability-to-pay calculation. For the document lookup, see the financial analysis document reference. To prepare for review, a 15-minute consultation is free.
1. Income Verification: All Sources
The IRS verifies income against internal records — prior returns, third-party information returns, and bank deposit analysis when available. Form 433 disclosure is the starting point; the IRS cross-checks against actual data.
If this is you: Your income is primarily W-2 wages with minimal other sources. Verification is straightforward. If self-employment, investment, or rental income is involved, the IRS will look deeper — bank statements, 1099-K, prior-year reporting patterns.
Income sources considered:
- Wages (W-2). Current pay stub, YTD gross.
- Self-employment (Schedule C / E). Current year and prior year; bank deposits.
- Rental income (Schedule E). Gross rents, actual expenses.
- Interest and dividends. 1099-INT and 1099-DIV.
- Social Security and retirement. SSA-1099, 1099-R.
- Alimony. Pre-2019 divorces; court-ordered.
- Other income. Partnership K-1, S-corporation K-1, trust.
Income Verification Strategy
- Pull IRS wage and income transcript. Confirms what the IRS already sees.
- Include all income on Form 433. Under-reporting creates credibility issues.
- Document variable income honestly. Self-employed may need 12 months of averages.
- Reconcile bank deposits to income. Especially for self-employment.
- Exclude non-taxable receipts. Loans, gifts, insurance recovery.
2. Asset Valuation: Quick-Sale Value
The IRS values assets at Quick-Sale Value (QSV) — typically 80% of fair market value — minus encumbrances (loans, liens). QSV is the core of Net Realizable Equity in OIC and is also used in IA and PPIA analysis.3
If this is you: You have assets — house, vehicles, retirement, investments. The IRS will value these at 80% of FMV and subtract loans. The result is the equity available to the IRS. Accurate valuation matters; over-valuation inflates RCP and ability-to-pay.
Asset valuation method:
- Real estate. FMV by appraisal or comparable sales; 80% QSV; minus mortgage.
- Vehicles. NADA or Kelley Blue Book value; 80% QSV; minus loan.
- Bank accounts. Current balance, 100% value (not QSV).
- Retirement accounts. Current balance minus age-adjusted tax on early withdrawal; discretionary discount.
- Business interests. Complex; often going-concern vs. liquidation analysis.
- Collectibles, art, jewelry. Market value; 80% QSV.
3. Expense Analysis: Lesser of Actual or Standard
The IRS applies Collection Financial Standards to allowable expenses — lesser of actual or standard by category, with above-standard amounts allowed only as documented Necessary Expenses.
If this is you: You have specific expenses that may exceed standards. Housing in high-cost areas, medical, dependent care, court-ordered payments. Careful documentation produces higher allowances. Generic “my rent is high” does not.
4. Ability-to-Pay Calculation
The final stage computes monthly disposable income = net income minus total allowable expenses. The result drives the monthly payment in IA, PPIA, and the future income component of OIC RCP.
If this is you: The ability-to-pay number determines your monthly obligation. Small differences in the expense analysis compound across years. Professional review can identify legitimate expense adjustments that materially reduce the monthly payment.
IRS financial analysis in progress? The math is set at the initial review. Correcting errors later requires appeals or modifications. Book a consultation to scope the analysis before submission.
Financial Analysis Document Lookup
| Document | Purpose |
|---|---|
| Form 433-F | Collection Information Statement (simplified) |
| Form 433-A | CIS (full individual) |
| Form 433-B | CIS (business) |
| Form 433-A (OIC) / 433-B (OIC) | CIS for OIC |
| Form 4506-T | Request for Transcript |
| Collection Financial Standards | Allowable expense tables |
| IRM 5.15.1 | Financial Analysis Handbook |
| IRM 5.8.5 | OIC RCP calculation |
| Publication 594 | IRS Collection Process |
Statute and Financial Analysis
- CSED: 10 years from assessment. Ability-to-pay multiplied by remaining CSED defines maximum IA duration.
- Refund statute. 3 years from filing or 2 years from payment.
- PPIA 2-year review. New financial analysis.
- OIC 5-year covenant. Ongoing compliance required.
Financial Analysis Outcomes
| Preparation Quality | Typical Outcome |
|---|---|
| Complete disclosure + Necessary Expense documentation | Lower monthly payment |
| Standard-compliant disclosure with no adjustments | IRS-standard monthly payment |
| Incomplete disclosure | IRS requests more information; extends timeline |
| Misrepresentation | Credibility damage; possible fraud exposure |
Financial Analysis Escalation Pathway
Initial Submission to Analysis
Form 433 submitted. IRS cross-checks against internal records. May request additional documentation.
Analysis to Proposal
IRS calculates ability-to-pay. Monthly payment proposed for IA or PPIA. Offer acceptance or rejection for OIC.
Disagreement to Appeals
Taxpayer disagreement on ALE application or asset valuation can be appealed via CAP or CDP.
The First 48 Hours of Financial Analysis Prep
- Pull IRS wage and income transcript.
- Compile 3 months of bank statements.
- List all assets with documentation.
- Compile all expenses with receipts.
- Apply Collection Financial Standards.
- Identify Necessary Expenses above standards.
- Prepare Form 433 with supporting documentation.
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Brotman Law has been recognized by Inc. Magazine as one of California’s fastest-growing law firms. We have navigated thousands of IRS financial analyses across all collection resolution types, with outcomes consistently better than self-represented analyses. Our office is based in San Diego.
The ROI Question
Financial analysis outcomes compound across years. A $200/month reduction in ability-to-pay over a 7-year IA is $16,800 in savings. Professional preparation of the financial analysis typically costs a fraction of the aggregate savings it produces.
Dealing with IRS Collections Activity?
Whether you’ve received a final notice of intent to levy, a notice of federal tax lien, or a revenue officer has made contact, the collections process has timelines that work against you if you wait. Most situations have resolution paths — but the options narrow as the IRS moves further into enforcement. We can identify where you are in the process and what makes sense for your situation.
Discuss My Collections Situation → Or call: (619) 378-3138
When to Engage an Attorney for Financial Analysis
- Balance over $50,000.
- Self-employment or business income.
- Complex assets. Business interests, real estate, retirement.
- Above-standard necessary expenses.
- Prior analysis produced unacceptable outcome.
- OIC RCP with asset valuation issues.
- Business financial analysis.
Any of the above apply?
A 15-minute consultation is free. We prepare and review financial analysis.
Guide Chapters
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Frequently Asked Questions
How does the IRS analyze my finances?
Four stages: income verification (cross-check against internal records), asset valuation (quick-sale value minus encumbrances), expense analysis (lesser of actual or Collection Financial Standards), and ability-to-pay calculation (net income minus total allowable expenses). The result drives IA, PPIA, OIC, and CNC decisions.
What is the IRS looking at during financial review?
All income sources, all assets and their equity, all expenses compared to Collection Financial Standards, and the resulting monthly disposable income. The IRS cross-checks disclosure against internal data — prior returns, 1099s, and in some cases summoned bank records.
What is Quick-Sale Value?
The IRS’s asset valuation method — typically 80% of fair market value, recognizing that a forced sale produces less than a retail sale. QSV minus encumbrances (mortgages, loans) equals Net Realizable Equity. QSV is used in OIC RCP calculation and in IA asset analysis.
Will the IRS use my actual expenses or the standards?
Lesser of the two per category. Below-standard actual expenses are used. Above-standard actual expenses are capped at the standard unless documented as Necessary Expense under IRM 5.15.1. Medical, court-ordered, dependent care, secured debt in good standing are common Necessary Expense categories.
How does the IRS value my home?
Fair market value from comparable sales, Zillow, or formal appraisal. QSV is 80% of FMV. Minus mortgage balance. The result is the home equity available to IRS. Primary residences are rarely seized but equity affects RCP in OIC.
Does the IRS look at my bank accounts?
Yes. Current bank balances are part of the financial analysis. The IRS may request 3 to 12 months of bank statements to verify income deposits and expense patterns. Summons to the bank can produce statements the taxpayer has not voluntarily provided.
What if I have variable income?
The IRS typically averages variable income over 12 months for stability. Seasonal workers, self-employed with fluctuating revenue, and commission-based earners use averages. Providing accurate monthly data for the prior year is important.
Can I negotiate my ability-to-pay calculation?
Yes, within Collection Financial Standards. Adjustments for Necessary Expenses, correction of IRS arithmetic errors, and recalculation based on new data are all available. Above-standard adjustments require documentation and justification.
How long does financial analysis take?
ACS cases: 30 to 90 days. Revenue Officer cases: 60 to 180 days. OIC cases: 6 to 12 months. Complex business cases can take longer. Delays typically reflect additional IRS information requests or IDRs.
What is the IRS's quick-sale value discount for?
It recognizes that forced sale or expedited disposition typically produces less than retail value. Real estate sold quickly may bring 70% to 80% of appraised value. The IRS standard 80% approximates this discount. Some assets (financial accounts, vehicles with specific valuations) may use different discount rates.
Does retirement account balance count in financial analysis?
Yes, but with age-adjusted discount. A taxpayer under 59½ faces 10% early withdrawal penalty plus income tax on distribution. The IRS discounts the account balance accordingly. Older taxpayers’ retirement accounts count at fuller value.
Can I include my credit card payments in expenses?
Generally no. Unsecured credit card minimum payments are not Necessary Expenses under IRM 5.15.1. The IRS treats credit card balances as debt available to pay tax, not as a protected monthly obligation. Secured debt (car loan, mortgage) is allowed.
What happens if I under-disclose?
Credibility damage. The IRS cross-checks disclosure against internal data. Undisclosed income or assets identified by the IRS reduces the likelihood of favorable outcomes. In fraud-adjacent cases, under-disclosure can support civil fraud penalties or criminal referral. Full disclosure is the right strategy.
Next Steps in This Guide
If you are going through IRS financial review, a 15-minute consultation is free.
- Financial analysis framework: IRM 5.15.1.
- Documentation standards drawn from Brotman Law practice.
- Quick-Sale Value: IRM 5.8.5.
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