IRS Enforced Collection Actions: Challenges and Responses to Federal Tax Liens and Levies

This CLE/CPE course will provide tax attorneys, CPAs and enrolled agents with a comprehensive and practical guide to navigating the process of responding to and challenging IRS collection actions, both Notice of Intent to Levy and Notice of Federal Tax Lien. The panel will discuss the lien process, detailing the stages of IRS collection activity, and provide useful tools for challenging or delaying lien proceedings. The webinar will also offer guidance on the formal appeals process, including bases for appeal, and useful tools for compiling and submitting the appeal correspondence and documentation.

One of the most frightening events for delinquent taxpayers is receiving an IRS notice indicating that the Service is pursuing an enforced collection action. Because taxpayers often delay in engaging representation in dealing with IRS correspondence, tax counsel often becomes involved only after the time period in which negotiation and resolution can be handled by correspondence and payment plans.

Tax counsel must accordingly have an advanced understanding of the IRS enforced collection process to effectively defend taxpayers who find themselves subject to lien or levy notification.

The key statutory tools available to the IRS in collecting alleged tax deficiencies are lien, levy and asset seizure powers. Each of these actions has a defined course of escalating notice and response requirements. Depending on the nature of the tax due and the stage of the collection process, tax counsel has available defense and mitigation remedies to each collection action.

Knowing what tools are available to challenge IRS enforced collections enables tax counsel to properly respond to IRS actions. Listen as our experienced panel provides a thorough, “beyond-the-basics” guide to effectively navigating the IRS collection process once asset attachment or seizure is on the table as an option for collecting delinquent tax.