We all know that CNC status is impermanent; the magic word in “Currently Not Collectible” is “Currently.” Hit the lottery, get named in the will, or score the dream job and you’re back in IRS’ crosshairs, with interest and chops.

But should you stipulate to your deficiency-plus?

That’s the tactical dilemma for Adrian Wright, Docket No. 9547-25L, filed 9/17/26. Adrian, pro se of course, petitions a CDP, from which issues Letter 4223, declaring “Case Closed – Currently Not Collectible.” Order, at p. 2.

IRS tries twice to draft a stiped decision with below-the-line language affirming Adrian’s CNC status. Adrian refuses.

STJ Peter J. (“HB”) Panuthos, master headbanger, dismisses Adrian’s Zuch claim, because Zuch involved a tax liability satisfied in full, so further or future collection is not possible. Jennifer Zuch wanted to contest how the liability was paid, and that she cannot do in Tax Court. Adrian’s tax liability is still open; IRS just can’t grab to satisfy it yet.

STJ HB Panuthos goes to his usual move: if y’all don’t settle, I’ll do it for you or you can try the case, and sotto voce, you won’t like the result.

“If petitioner continues to decline to sign a stipulated decision, the Court would consider an appropriate motion to enter a decision or the Court may set this matter for trial in order to resolve any remaining issues.” Order, at p. 3.

OK, so what should Adrian do? Remember Matty Dean Vigon, or if you don’t, see my blogpost “‘Crafty – Akin to the Weasel,'” 7/24/17.

What would you advise, reader? Stipulate a decision with a below-the-line CNC saver? Insist on the stiped decision stating CNC above the line, making it part of the decision rather than a contract between the parties? Or let IRS enter decision on liability with no mention of CNC?

There is no correct answer.