The Tax Times: When Taxpayers Do Not Cooperate With IRS' Request For Support of Expenses on Form 433-A

Friday, August 8, 2025

When Taxpayers Do Not Cooperate With IRS' Request For Support of Expenses on Form 433-A

When taxpayers fall behind on their federal taxes, they often hope for alternatives to harsh collection tactics. But a recent Tax Court case involving an Iowa couple, Chad and Tina Mackland, is a strong reminder: the IRS will expect real cooperation before granting relief (Mackland, T.C. Memo. 2025-69).

The Macklands owed taxes for two years but hadn’t paid. When the IRS tried, unsuccessfully to collect, it issued them a notice proposing a levy on their assets. In response, the couple requested a Collection Due Process (CDP) hearing and said they wanted an installment agreement. They explained that they were facing serious health and employment problems and hoped to use their home equity to pay off the debt, though a federal tax lien was complicating matters.

The IRS Appeals officer handling their case asked the Macklands for updated financial records and proof of hardship, basic steps in considering any payment plan. But the Macklands never supplied the documents the IRS needed, despite having nine months to do so.

With no new information, the Appeals officer went ahead and sustained the proposed levy. Unsatisfied, the Macklands took the matter to Tax Court, claiming the IRS official had been too harsh and asking the court to force the IRS to give them the payment plan they wanted.

The Tax Court disagreed with the Macklands. The court said the IRS officer had actually shown “extreme forbearance” and gave the couple ample time and opportunity to cooperate. Because the Macklands didn’t provide the documents or evidence the IRS requested, the court found that the IRS acted reasonably in moving forward with the collection action.

What does this mean for taxpayers?

If you’re seeking relief from the IRS, whether it’s an installment agreement, an offer in compromise, or another option, you have to meet them halfway. That means promptly providing all requested forms and financial documentation.

Courts are unlikely to side with a taxpayer who fails to cooperate, and the IRS can move forward with levies or other collection actions if you do not play your part.

Have an IRS Tax Problem?