Brian I think you are correct. If they provide a 433-A the IRS will want the $5,000. You can call and ask if the non-streamlined $250,000 over CSED is available and what that would be. I would play it as “Client’s are struggling and asked if the plan could be reduced, and dont want to spend the money doing a 433-A and submitting all that. Maybe the IRS can adjust it, but dont be surprised if they wont without a 433-A. If they wont then just state you’ll explain it to the clients and see what they want to do and if they want to pursue modifying it you’ll call back.