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Pardon my being tardy for this party. Generally, a CIS (form 433 series) is not required when a taxpayer’s balance is less than $10k and the taxpayer is either unemployed or solely receiving SS income (See IRM sec.184.108.40.206.9).
Bear in mind, the CNC status is supposed to be reviewed annually. So, yes, if you tell the IRS that your client is unemployed or solely collecting SS income, they usually check the transcripts to confirm that. In the case of this year’s pandemic, some reps will just input the CNC without the CIS but when the transcripts come out the following year showing that they taxpayer generated taxable wages and/or self-employment income then the taxpayer will be contacted to provided an updated CIS or set up an IA.