Bryan, try and make the client CNC. CNC does not extend the statute. So do the 433-A analysis. if they are positive see if there are some financial moves you can make to get them into CNC – like health insurance, etc. If you go through the Offer program in the members area we do a case study like this. I would try and get the client cnc and run out the statute. Worse case is set up an installment agreement. The statute will toll while it is pending but will start running again once the agreement is approved.