Trust Fund Recovery Penalty – Fast Track Mediation – Former IRS Agents – Tax Help

Fresh Start Tax LLC         A Professional Tax Firm          Since 1982         Affordable Professional Tax Representation

If you need help with a proposed trust fund penalty assessment, call us today to get the very best  of professional tax representation.

As a former IRS Revenue Officer I have worked thousands of trust fund cases, I am a true tax expert.

  Appealing the Proposed Assessment Trust Fund Penalty Assessment

Letter 1153 advises the responsible party of his or her appeal rights.

The form that the appeal must take is based on the dollar amount of the proposed assessment.

 The Letter 1153  also advises the responsible party that they may contact the  IRS  Revenue Officer within ten days of the Letter 1153 if:

They don’t agree with the proposed trust fund recovery assessment and have additional information to support their case

If you wish to try to resolve the matter informally:

In order to preserve their appeal rights, the responsible party must mail (or fax, if applicable) a written appeal within 60 days of the mailing or personal delivery of the letter (75 days if the letter is addressed to the responsible party outside of the United States). If the revenue officer does not agree with the information submitted informally, then the revenue officer should advise the taxpayer that they must follow the appeal procedures included in the Letter 1153(DO).

TFRP cases are also eligible for Fast Track Mediation (FTM). This program is designed to expedite case resolution since the entire process normally takes 30-40 days to complete. Additional information can be found in Publication 3605, Fast Track Mediation – A Process for Prompt Resolution of Tax Issues. Publication 3605 should be provided to the taxpayer to explain the FTM process.

The ASED is only extended for cases where the taxpayer files a proper appeal within the allowable time period; FTM has no impact on the ASED or the regular appeals procedures. Advise the taxpayer that even if they choose FTM, they must continue to follow the procedures in Letter 1153(DO) by filing the appropriate request within 60 days of issuance of the Letter 1153(DO) if they wish to have the case considered by the Appeals office in case the FTM is not resolved in their favor.

Both the taxpayer and the revenue officer must agree to mediate. The taxpayer must have completed a Form 4180, Report of Interview with Individual Relative to Trust Fund Recovery Penalty or Personal Liability for Excise Tax, and supplied all requested back-up documentation related to the trust fund recovery penalty investigation. To initiate the FTM process, the revenue officer will complete an “Agreement to Mediate” and a ” Summary of Issues” and forward the documents to Appeals within three days of securing the taxpayer’s signature.

If the parties do not reach an agreement, then the case will be forwarded to Appeals through Advisory if the taxpayer followed the instructions in Letter 1153(DO) regarding the formal appeal process. The case will then be assigned to a different Appeals officer. If the taxpayer did not follow the formal appeals process, the case should be forwarded for assessment. The taxpayer may still file a claim for refund after assessment if appropriate payment has been made.

If the revenue officer agrees with the information that was submitted informally or if the parties reach an agreement through the mediation process, then the revenue officer should change the determination by following the procedures in IRM 5.7.6.1.7.

If the revenue officer does not change the determination based on the information submitted informally, he or she should advise the taxpayer to follow the formal protest procedures outlined in Letter 1153(DO) in order to protect their appeal rights.

If the amount of tax liability proposed for the the period is:
Dollar Amount Type of Appeal
$25,000 or Less Small Case Request
More than $25,000 Formal Written Protest

If one tax period is more than $25,000 the taxpayer must submit a formal Written Protest.

IRM 5.7.6.1.4 contains the guidelines on the information that the taxpayer should include in a Small Case Request. IRM 5.7.6.1.5 contains the information that the taxpayer should include in a Formal Written Protest. The responsible party should submit any additional information or documentation that he or she wants the Settlement Officer/Appeals Officer to consider.
Note:

Usually appeals of penalty cases involve issues of responsibility and/or willfulness or how the penalty was calculated.

IRS PROBLEM – IMMEDIATE & AFFORDABLE TAX RELIEF – TAX ATTORNEYS, FORMER IRS AGENTS – IRS Tax Experts – Columbia, Charleston, Sumter, Orangeburg, Goose Creek- South Carolina

Fresh Start Tax LLC          Since 1982         IRS Tax Experts      A Professional Tax Firm      “A” Rated by the Better Business Bureau

Get immediate and permanent tax relief from a true professional tax firm. We are affordable, quick and trustworthy.

We are comprised of Board Certified Tax Attorneys, CPA’s and Former IRS Agents, Managers and Instructors. Since 1982, “A” rated by the BBB.

We have over 205 years of professional tax experience and over 60 years of direct IRS experience at the local, district and regional IRS offices.

We taught Tax Law a the IRS. We know all of the IRS tax policies and tax settlement procedures.

Areas of Professional Tax Practice:

  • Same Day IRS Tax Representation
  • Offers in Compromise or IRS Tax Debt Settlements
  • Immediate Release of IRS Bank Levies or IRS Wage Garnishments
  • Tax Relief from a IRS Bill, Letter or Notice of “Intent to Levy”
  • IRS Tax Audits
  • IRS Hardships Cases or Unable to Pay
  • Payment Plans, Installment Agreements, Structured agreements
  • Abatement of Penalties and Interest
  • State Sales Tax Cases
  • Payroll / Trust Fund Penalty Cases / 6672
  • Filing Late, Back, Unfiled Tax Returns
  • Tax Return Reconstruction if Tax Records are lost or destroyed

Our Company Resume: ( Since 1982 )

  • Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
  • On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
  • We taught Tax Law in the IRS Regional Training Center
  • Former IRS Agents, Managers and Instructors with over 60 years experience  in the local, district and regional IRS offices.
  • Highest Rating by the Better Business Bureau  “A”
  • Fast, affordable, and economical
  • Licensed and certified to practice in all 50 States
  • Nationally Recognized Veteran /Published  Former IRS Agent
  • Nationally Recognized Published EZINE Tax Expert
  • As heard on  GRACE 90.3 FM Monthly Radio Show-Business Weekly

How we Settle and Negotiate your case with the Internal Revenue Service:

1. We immediately send a power of attorney to the IRS letting them know we are now your tax representative. You will never have to speak to the IRS.

2. We will make sure all your tax returns are filed and current. If your tax returns are not up to date, the IRS will refuse to work your case. This is leverage that they use to get you compliant. We can pull tax transcripts, file and prepare your tax returns within days, even if you have lost your tax records.

3. The IRS requires a current financial statement. We will secure a required 433-A (IRS financial statement), verify the income and expenses and work out a settlement agreement. The IRS will require a closing settlement method for each case.

4. We review with our clients how they want to settle their case. We get them an agreement based on their current financial needs.

IRS Tax Settlement Agreements can be in different forms:

a. Hardship Settlements. Cases usually go into a 3 year suspended status because of an inability to pay. This is also called currently noncollectable. Your case will go into a hardship status because you do not have the income coming in to meet your current expenses. The IRS will use the National Standards Program to assess hardship.

b. Payment Agreements. Cases can be closed with agreed upon monthly installment payments to the IRS. We will review the different programs the IRS uses for the lowest possible amount required.

c. IRS Offer in Compromise. There are three types of OICs:

 The IRS may accept an Offer in Compromise based on three grounds:

1. Doubt as to Collectibility – Doubt exists that the taxpayer could ever pay the full amount of tax liability owed within the remainder of the statutory period for collection.

2. Doubt as to Liability – A legitimate doubt exists that the assessed tax liability is correct. Possible reasons to submit a doubt as to liability offer include:

(1) the examiner made a mistake interpreting the law,

(2) the examiner failed to consider the taxpayer’s evidence or

(3) the taxpayer has new evidence.

3. Effective Tax Administration / Exceptional Circumstances – There is no doubt that the tax is correct and there is potential to collect the full amount of the tax owed, but an exceptional circumstance exists that would allow the IRS to consider an OIC. To be eligible for compromise on this basis, a taxpayer must demonstrate that the collection of the tax would create an economic hardship or would be unfair and inequitable.

See our home page for more details about Fresh Start Tax L.L.C.            Thank You


IRS TAX RELIEF HELP – SETTLE TAX PROBLEM – TAX ATTORNEYS, FORMER IRS AGENTS – IRS Tax Experts – Columbia, Charleston, Sumter, Orangeburg, Goose Creek- South Carolina

Fresh Start Tax LLC            Since 1982             IRS Tax Experts          A Professional Tax Firm         “A” Rated by the Better Business Bureau

If you need immediate relief from any IRS problem call us today to hear all of your tax options from a professional tax firm.

We have over 205 years of professional tax experience and over 60 years of directly working for the IRS in the local, district and regional offices.

We taught tax law at the  Regional Training office of the Internal Revenue Service. We know and taught all the tax policies at the IRS. We are Collection Division specialists.

Call us today for a no cost professional tax consult and speak to either a Board Certified Tax Attorney, CPA or Former IRS Agents.

Fresh Start Tax L.L.C. is one of the premier tax resolution firms in the country. We deal with all types of civil cases including individuals, businesses, non-profits, partnerships and corporations. We have staff that specialize in every facet of IRS Tax Representation.
We know all the IRS tax strategies because of our extensive IRS working backgrounds. We were Former IRS Certified Tax Instructors that taught IRS Tax Law in the IRS Regional Training Center. Some of our many specialties include the following:


Areas of Professional Tax Practice:

  • Same Day IRS Tax Representation
  • Offers in Compromise or IRS Tax Debt Settlements
  • Immediate Release of IRS Bank Levies or IRS Wage Garnishments
  • Tax Relief from a IRS Bill, Letter or Notice of “Intent to Levy”
  • IRS Tax Audits
  • IRS Hardships Cases or Unable to Pay
  • Payment Plans, Installment Agreements, Structured agreements
  • Abatement of Penalties and Interest
  • State Sales Tax Cases
  • Payroll / Trust Fund Penalty Cases / 6672
  • Filing Late, Back, Unfiled Tax Returns
  • Tax Return Reconstruction if Tax Records are lost or destroyed

Our Company Resume: ( Since 1982 )

  • Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
  • On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
  • We taught Tax Law in the IRS Regional Training Center
  • Former IRS Agents, Managers and Instructors with over 60 years experience  in the local, district and regional IRS offices.
  • Highest Rating by the Better Business Bureau  “A”
  • Fast, affordable, and economical
  • Licensed and certified to practice in all 50 States
  • Nationally Recognized Veteran /Published  Former IRS Agent
  • Nationally Recognized Published EZINE Tax Expert
  • As heard on  GRACE 90.3 FM Monthly Radio Show-Business Weekly


See our Home Page for more details     Thank you



IRS NOTICE OF INTENT TO LEVY, SEIZURE, LATE TAX RETURNS, SETTLE – TAX ATTORNEYS, FORMER AGENTS – IRS Tax Experts – Columbia, Charleston, Sumter, Orangeburg, Goose Creek- South Carolina

Fresh Start Tax

 

 

Fresh Start Tax LLC           IRS Tax Experts         Since 1982          A Professional Tax Firm       “A” Rated by the Better Business Bureau

Get immediate relief from the IRS. We can stop the IRS today with one phone call.

We have over 205 years of professional tax experience and over 60 years of direct work experience at the IRS in the local, regional and district offices of the IRS. We taught Tax Law at the IRS Regional Offices.

Hire trust, experience and professionalism.

Call us for a no cost tax consultation from a true tax professional. You will never speak to the IRS.


 Areas of Professional Tax Practice:

 

  • Same Day IRS Tax Representation
  • Offers in Compromise or IRS Tax Debt Settlements
  • Immediate Release of IRS Bank Levies or IRS Wage Garnishments
  • Tax Relief from a IRS Bill, Letter or Notice of “Intent to Levy”
  • IRS Tax Audits
  • IRS Hardships Cases or Unable to Pay
  • Payment Plans, Installment Agreements, Structured agreements
  • Abatement of Penalties and Interest
  • State Sales Tax Cases
  • Payroll / Trust Fund Penalty Cases / 6672
  • Filing Late, Back, Unfiled Tax Returns
  • Tax Return Reconstruction if Tax Records are lost or destroyed

 

Our Company Resume: ( Since 1982 )

 

 

  • Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
  • On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
  • We taught Tax Law in the IRS Regional Training Center
  • Former IRS Agents, Managers and Instructors with over 60 years experience  in the local, district and regional IRS offices.
  • Highest Rating by the Better Business Bureau  “A”
  • Fast, affordable, and economical
  • Licensed and certified to practice in all 50 States
  • Nationally Recognized Veteran /Published  Former IRS Agent
  • Nationally Recognized Published EZINE Tax Expert
  • As heard on  GRACE 90.3 FM Monthly Radio Show-Business Weekly

 

How we can immediately get Notices of Bank Levy and Wage Garnishment  Released.

 



As former IRS Agents, Managers and Instructors we have issued thousands of IRS Wage/Garnishment and Bank Levies. We know exactly how to quickly get them
released. We have what it takes.

1. We immediately send a power of attorney to the IRS letting them know we are now your representative. You will never have to speak to them.

2. We will make sure all your tax returns are filed and current. If your tax returns are not up to date, the IRS will refuse to work your case. This is leverage that they use to get you compliant.

We can pull tax transcripts, file and prepare your tax returns within days, even if you have lost your tax records.

3. The IRS requires a current financial statement. We will secure a required 433-F (IRS financial statement), verify the income and expenses and work out a settlement agreement.

The IRS will require a closing settlement method for each case.

4. We review with our clients how they want to settle their case. We get them an agreement based on their current financial needs.

 

IRS Tax Settlement Agreements can be in different forms:

 

 

a. Hardship Settlements. Cases usually go into a 3 year suspended status because of an inability to pay. This is also called currently noncollectable. Your case will go into a hardship status because you do not have the income coming in to meet your current expenses.

The IRS will use the National Standards Program to assess hardship.

b. Payment Agreements. Cases can be closed with agreed upon monthly installment payments to the IRS.

We will review the different programs the IRS uses for the lowest possible amount required.

 

c. Offer in Compromise. There are three types of OICs:

 

The IRS may accept an Offer in Compromise based on three grounds:

1. Doubt as to Collectibility – Doubt exists that the taxpayer could ever pay the full amount of tax liability owed within the remainder of the statutory period for collection.

2. Doubt as to Liability – A legitimate doubt exists that the assessed tax liability is correct. Possible reasons to submit a doubt as to liability offer include:

(1) the examiner made a mistake interpreting the law,

(2) the examiner failed to consider the taxpayer’s evidence or

(3) the taxpayer has new evidence.

3. Effective Tax Administration/ Exceptional Circumstances – There is no doubt that the tax is correct and there is potential to collect the full amount of the tax owed, but an exceptional circumstance exists that would allow the IRS to consider an OIC.

To be eligible for compromise on this basis, a taxpayer must demonstrate that the collection of the tax would create an economic hardship or would be unfair and inequitable.


See our home page for more details   Thank you

 

IRS NOTICE OF INTENT TO LEVY, SEIZURE, LATE TAX RETURNS, SETTLE – TAX ATTORNEYS,

 

Bank Levy, Wage Garnishments – Immediate Tax Help, Levy Relief – Tax Attorneys, Former IRS Agents – IRS Tax Experts – Columbia, Charleston, Sumter, Orangeburg, Goose Creek- South Carolina

Fresh Start Tax

Fresh Start Tax LLC           Since 1982           IRS Tax Experts          A Professional Tax Firm           “A” Plus  Rated by the Better Business Bureau

Get immediate releases of  Tax Levies!   Get your case settled once and for all.

Let Former IRS Agents, Managers, and Instructors who have over 60 years with the IRS in the local, regional and district offices get you immediate levy relief.

We know who to call. We not only will get you immediate tax relief, we will also settle your case as well.

Hire trust, experience, and professionalism.

You will never speak to the IRS.

 

 Areas of Professional Tax Practice:

 

 

  • Same Day IRS Tax Representation
  • Offers in Compromise or IRS Tax Debt Settlements
  • Immediate Release of IRS Bank Levies or IRS Wage Garnishments
  • Tax Relief from a IRS Bill, Letter or Notice of “Intent to Levy”
  • IRS Tax Audits
  • IRS Hardships Cases or Unable to Pay
  • Payment Plans, Installment Agreements, Structured agreements
  • Abatement of Penalties and Interest
  • State Sales Tax Cases
  • Payroll / Trust Fund Penalty Cases / 6672
  • Filing Late, Back, Unfiled Tax Returns
  • Tax Return Reconstruction if Tax Records are lost or destroyed

 

Our Company Resume: ( Since 1982 )

 

 

  • Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
  • On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
  • We taught Tax Law in the IRS Regional Training Center
  • Former IRS Agents, Managers and Instructors with over 60 years experience  in the local, district and regional IRS offices.
  • Highest Rating by the Better Business Bureau  “A”
  • Fast, affordable, and economical
  • Licensed and certified to practice in all 50 States
  • Nationally Recognized Veteran /Published  Former IRS Agent
  • Nationally Recognized Published EZINE Tax Expert
  • As heard on  GRACE 90.3 FM Monthly Radio Show-Business Weekly

 

How we can immediately get Notices of Bank Levy and Wage Garnishment  Released.

 



As former IRS Agents, Managers and Instructors we have issued thousands of IRS Wage/Garnishment and Bank Levies. We know exactly how to quickly get them released. We have what it takes.

1. We immediately send a power of attorney to the IRS letting them know we are now your representative. You will never have to speak to them.

2. We will make sure all your tax returns are filed and current. If your tax returns are not up to date, the IRS will refuse to work your case. This is leverage that they use to get you compliant. We can pull tax transcripts, file and prepare your tax returns within days, even if you have lost your tax records.

3. The IRS requires a current financial statement. We will secure a required 433-F (IRS financial statement), verify the income and expenses and work out a settlement agreement. The IRS will require a closing settlement method for each case.

4. We review with our clients how they want to settle their case. We get them an agreement based on their current financial needs.

 

IRS Tax Settlement Agreements can be in different forms:

 

 

a. Hardship Settlements. Cases usually go into a 3 year suspended status because of an inability to pay. This is also called currently noncollectable. Your case will go into a hardship status because you do not have the income coming in to meet your current expenses. The IRS will use the National Standards Program to assess hardship.

b. Payment Agreements. Cases can be closed with agreed upon monthly installment payments to the IRS. We will review the different programs the IRS uses for the lowest possible amount required.

 

c. Offer in Compromise. There are three types of OICs:

 

The IRS may accept an Offer in Compromise based on three grounds:

1. Doubt as to Collectibility – Doubt exists that the taxpayer could ever pay the full amount of tax liability owed within the remainder of the statutory period for collection.

2. Doubt as to Liability – A legitimate doubt exists that the assessed tax liability is correct. Possible reasons to submit a doubt as to liability offer include:

(1) the examiner made a mistake interpreting the law,

(2) the examiner failed to consider the taxpayer’s evidence or

(3) the taxpayer has new evidence.

3. Effective Tax Administration/ Exceptional Circumstances – There is no doubt that the tax is correct and there is potential to collect the full amount of the tax owed, but an exceptional circumstance exists that would allow the IRS to consider an OIC.

To be eligible for compromise on this basis, a taxpayer must demonstrate that the collection of the tax would create an economic hardship or would be unfair and inequitable.


See our home page for more details   Thank you

 

Bank Levy, Wage Garnishments – Immediate Tax Help /  Levy Relief –  Tax Attorneys, Former IRS Agents


IRS Tax Levy – Immediate Tax Relief – Tax Attorneys, Former IRS Agents – IRS Tax Experts – Columbia, Charleston, Sumter, Orangeburg, Goose Creek- South Carolina

Fresh Start Tax LLC        Since 1982      A Professional Tax Firm     IRS Tax Experts       “A” Rated by the Better Business Bureau

We can get immediate releases of Federal Tax Levies both on bank accounts and on wage levies.

We get immediate tax results. You will never speak to the IRS.

We are comprised of Board Certified Tax Attorneys, Lawyers, CPA’s and Former IRS Agents, Managers and Instructors. We have over 205 years of professional tax experience and over 60 years of working directly for the IRS in the local, district and regional offices of the IRS.

Do not hire a tax mill, you may be scammed or ripped off. Hire a true professional tax firm.

Fresh Start Tax L.L.C. is one of the premier tax resolution firms in the country. We deal with all types of civil cases including individuals, businesses, non-profits, partnerships and corporations. We have staff that specialize in every facet of IRS Tax Representation.
We know all the IRS tax strategies because of our extensive IRS working backgrounds. We were Former IRS Certified Tax Instructors that taught IRS Tax Law in the IRS Regional Training Center. Some of our many specialties include the following:

Areas of Professional Tax Practice:

  • Same Day IRS Tax Representation
  • Offers in Compromise or IRS Tax Debt Settlements
  • Immediate Release of IRS Bank Levies or IRS Wage Garnishments
  • Tax Relief from a IRS Bill, Letter or Notice of “Intent to Levy”
  • IRS Tax Audits
  • IRS Hardships Cases or Unable to Pay
  • Payment Plans, Installment Agreements, Structured agreements
  • Abatement of Penalties and Interest
  • State Sales Tax Cases
  • Payroll / Trust Fund Penalty Cases / 6672
  • Filing Late, Back, Unfiled Tax Returns
  • Tax Return Reconstruction if Tax Records are lost or destroyed

Our Company Resume: ( Since 1982 )

  • Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
  • On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
  • We taught Tax Law in the IRS Regional Training Center
  • Former IRS Agents, Managers and Instructors with over 60 years experience  in the local, district and regional IRS offices.
  • Highest Rating by the Better Business Bureau  “A”
  • Fast, affordable, and economical
  • Licensed and certified to practice in all 50 States
  • Nationally Recognized Veteran /Published  Former IRS Agent
  • Nationally Recognized Published EZINE Tax Expert
  • As heard on  GRACE 90.3 FM Monthly Radio Show-Business Weekly


How we can immediately get Notices of Bank Levy and Wage Garnishment  Released.

As former IRS Agents, Managers and Instructors we have issued thousands of IRS Wage/Garnishment and Bank Levies. We know exactly how to quickly get them released. We have what it takes.

1. We immediately send a power of attorney to the IRS letting them know we are now your representative. You will never have to speak to them.

2. We will make sure all your tax returns are filed and current. If your tax returns are not up to date, the IRS will refuse to work your case. This is leverage that they use to get you compliant. We can pull tax transcripts, file and prepare your tax returns within days, even if you have lost your tax records.

3. The IRS requires a current financial statement. We will secure a required 433-F (IRS financial statement), verify the income and expenses and work out a settlement agreement. The IRS will require a closing settlement method for each case.

4. We review with our clients how they want to settle their case. We get them an agreement based on their current financial needs.

IRS Tax Settlement Agreements can be in different forms:

a. Hardship Settlements. Cases usually go into a 3 year suspended status because of an inability to pay. This is also called currently noncollectable. Your case will go into a hardship status because you do not have the income coming in to meet your current expenses. The IRS will use the National Standards Program to assess hardship.

b. Payment Agreements. Cases can be closed with agreed upon monthly installment payments to the IRS. We will review the different programs the IRS uses for the lowest possible amount required.

c. Offer in Compromise. There are three types of OICs:

 The IRS may accept an Offer in Compromise based on three grounds:

1. Doubt as to Collectibility – Doubt exists that the taxpayer could ever pay the full amount of tax liability owed within the remainder of the statutory period for collection.

2. Doubt as to Liability – A legitimate doubt exists that the assessed tax liability is correct. Possible reasons to submit a doubt as to liability offer include:

(1) the examiner made a mistake interpreting the law,

(2) the examiner failed to consider the taxpayer’s evidence or

(3) the taxpayer has new evidence.

3. Effective Tax Administration/ Exceptional Circumstances – There is no doubt that the tax is correct and there is potential to collect the full amount of the tax owed, but an exceptional circumstance exists that would allow the IRS to consider an OIC. To be eligible for compromise on this basis, a taxpayer must demonstrate that the collection of the tax would create an economic hardship or would be unfair and inequitable.

 

Levy

A levy is a legal seizure of your property to satisfy a tax debt. Levies are different from liens. A lien is a claim used as security for the tax debt, while a levy actually takes the property to satisfy the tax debt.

If you do not pay your taxes (or make arrangements to settle your debt), the IRS may seize and sell any type of real or personal property that you own or have an interest in. For instance,

  • We could seize and sell property that you hold (such as your car, boat, or house), or
  • We could levy property that is yours but is held by someone else (such as your wages, retirement accounts, dividends, bank accounts, licenses, rental income, accounts receivables, the cash loan value of your life insurance, or commissions).

We usually levy only after these three requirements are met:

  • We assessed the tax and sent you a Notice and Demand for Payment;
  • You neglected or refused to pay the tax; and
  • We sent you a Final Notice of Intent to Levy and Notice of Your Right to A Hearing (levy notice) at least 30 days before the levy. We may give you this notice in person, leave it at your home or your usual place of business, or send it to your last known address by certified or registered mail, return receipt requested. Please note: if we levy your state tax refund, you may receive a Notice of Levy on Your State Tax Refund, Notice of Your Right to Hearing after the levy.

You may ask an IRS manager to review your case, or you may request a Collection Due Process hearing with the Office of Appeals by filing a request for a Collection Due Process hearing with the IRS office listed on your notice. You must file your request within 30 days of the date on your notice. Some of the issues you may discuss include:

  • You paid all you owed before we sent the levy notice,
  • We assessed the tax and sent the levy notice when you were in bankruptcy, and subject to the automatic stay during bankruptcy,
  • We made a procedural error in an assessment,
  • The time to collect the tax (called the statute of limitations) expired before we sent the levy notice,
  • You did not have an opportunity to dispute the assessed liability,
  • You wish to discuss the collection options, or
  • You wish to make a spousal defense.

At the conclusion of your hearing, the Office of Appeals will issue a determination. You will have 30 days after the determination date to bring a suit to contest the determination. Refer to Publication 1660, Collection Appeal Rights (PDF), for more information. If your property is levied or seized, contact the employee who took the action. You also may ask the manager to review your case. If the matter is still unresolved, the manager can explain your rights to appeal to the Office of Appeals.


See our home page for more details   Thank you