Many years ago, the IRS came out with this little slogan, “a kinder, gentler IRS”. The question is,  “are they”?  A grizzly bear is soft and gentle at times, yet other times kills. Which one is the IRS? Ever since this slogan came out I laughed at the kinder gentler IRS. The truth be told,  it all depends on the agent and what type of day they are having. Like any business or job, when a case is worked by an agent, it has a certain personality to it just like a grizzly.
Some of the factors that determine how your case is going to be worked are based on the type of day the agent is having and their current life circumstances. Did they just have a review? Is management pressing new issues?  This all may affect your case. Management comes out with different programs throughout the years and if it is a program your case falls under, out comes the bear. There are too many factors that determine which side of the bear will show. It is important to remember first and foremost:
The IRS is a collection agency, imposing tax liens and tax levies to secure the national interest. They are interested in getting paid. That is their goal.
The bear is always happy when you you keep his belly full, i.e., you are current on tax deposits and are responsive to appointments and requests.
The reason you hire a true tax professional is to navigate your way through the process. The professional does not owe the tax and the IRS is in a less combative mode with them. As a general rule, once the professional is involved, your lien and levy chances are much diminished.
When I was an agent, I loved working with the professional because they helped me keep my deadlines.