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

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.

1. IRS enforced collection process
   1. Lien process
   2. Levy
   3. Asset seizures
2. Challenging liens
   1. Claiming IRS issued lien in error
   2. Appealing a lien filing under IRS Section 6320
   3. Obtaining partial or full discharge of lien
3. Challenging and defending against levy action
4. Assets exempt from levy

The panel will review these and other key issues:

• What is the correspondence chain leading up to enforced collection action by the IRS?
• What are the remedies and relief provisions to challenge or mitigate a tax lien?
• What are the bases of challenging tax levies and asset seizures?
• How to obtain full or partial discharge of tax liens

Learning Objectives

After completing this course, you will be able to:

• Recognize the escalation pattern of IRS Notices leading up to enforced collection actions
• Decide on strategies in responding to IRS Notice of Intent to Levy
• Discern options for negotiating with IRS during collection process
• Identify available challenges to IRS lien and levy actions

• Field of Study: Taxes
• Level of Knowledge: Intermediate
• Advance Preparation: None
• Teaching Method: Seminar/Lecture
• Delivery Method: Group-Internet (via computer)
• Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
• Prerequisite: Three years+ business, law or public firm experience at mid-level within the organization, handling tax matters for businesses and high net worth individuals; supervisory authority over other attorneys, preparers, accountants. Knowledge and understanding of IRS Enforced Collection Process, including the liens, levies and asset seizures. Familiarity with defending taxpayers in IRS audits, investigations and procedures.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).