IRS Collection / IRS Defense

Defending taxpayers from IRS enforcement and collection actions

If you owe the IRS and neglect to pay, they can levy your bank accounts, wages, and accounts receivable — and come to your door. Understanding the IRS collection process is the first step in defending yourself.

IRS Collection Timeline

After filing a return with a balance due, the IRS sends its first notice within 4-6 weeks. Additional notices follow every 4-6 weeks. When you receive a Certified Mail notice, a federal tax lien will be filed after 10 days.

Tax Lien (IRC 6321)

A tax lien is a public notification of your tax debt. It arises at the time of assessment and attaches to your property and real estate. Tax liens are picked up by credit reporting agencies and can severely damage your credit.

Important: A tax lien does not directly attach to bank accounts or wages — that requires a levy.

Tax Levy (IRC 6331)

A levy is more aggressive than a lien. The IRS sends a warning letter, followed by levy action within 30-90 days. IRC 6331 authorizes the Commissioner to levy all property or property rights belonging to the taxpayer.

Without communication, the IRS assigns a Revenue Officer — a collector, not an auditor — who will knock on your door.

Key IRS Notices

  • Letter 3172 — Notice of federal tax lien filing
  • Letter 1058 — Final notice of intent to levy
  • Form 12153 — Request for a Collections Due Process (CDP) hearing

Collections Due Process (CDP) Hearing

A CDP hearing is your right to challenge IRS collection actions before an independent Appeals officer. The Appeals officer considers:

  • Whether the IRS met all legal requirements
  • Taxpayer-specific issues and hardships
  • The balance between collection efficiency and the taxpayer's rights

A CDP hearing may result in an installment agreement or an offer in compromise. These require detailed financial disclosure through Forms 433-A and 656.

Take Action Now

The worst thing you can do is ignore IRS notices. Call (303) 626-7000 or email Phil@ColoradoLegal.com to discuss your IRS collection situation.

Ready to Get Started?

Contact Philip Falco, Attorney & CPA, for expert tax representation in Denver.