Guide · Tax

IRS Audits, Appeals, and Collection: A Comprehensive Guide to Examinations, Notices, Liens, Levies, and Settlements

26 U.S.C. § 6201

Type
Guide
Jurisdiction
National
Date
2023-12-25
Topic
Tax

This guide covers federal tax controversy from the first notice through final resolution. Part One separates examination from collection and explains why the distinction governs strategy, and Part Two covers examination types, information gathering, and the summons power. Part Three covers the notice of deficiency and the choice between Tax Court and refund litigation, and Part Four covers the appeals function. Part Five covers assessment and the limitations periods that quietly control everything, and Part Six covers liens, levies, and the collection hearings. Part Seven covers collection alternatives and their arithmetic, and Part Eight covers penalties, interest, and relief. Part Nine covers special situations and criminal exposure, and the remaining parts cover transcripts, documents, and worked examples.

IRS Audits, Appeals, and Collection: A Comprehensive Guide to Examinations, Notices, Liens, Levies, and Settlements

Tax > IRS Audits, Collection, and Taxpayer Rights | Published 25 December 2023 - Updated 26 October 2025 | UpLaw - uplaw.us

Part One — Two systems

📌 Examination determines liability. Collection enforces it. They have different notices, deadlines, personnel, and appeal rights, and the arguments available in one are largely unavailable in the other.

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