Guide · Tax
Tax Collection: A Comprehensive Guide to Liens, Levies, Installment Agreements, Offers in Compromise, and Collection Due Process
26 U.S.C. § 6201
- Type
- Guide
- Jurisdiction
- National
- Date
- 2024-12-09
- Topic
- Tax
This guide covers federal tax collection from assessment through resolution. It begins with the assessment and demand sequence that creates the lien automatically, then works through what property the lien reaches, how priority against competing creditors is decided, and the release, discharge, subordination, and withdrawal tools that make transactions possible while a balance remains. Levy chapters cover the surrender obligation, exempt property, continuous wage levy, jeopardy, and wrongful levy remedies for third parties. Resolution chapters address the compliance gate, installment agreements, offers in compromise and how reasonable collection potential is computed, uncollectible status, and penalty and interest abatement. Later chapters cover the collection due process hearing and its judicial review, the ten-year collection period and the events that suspend it, the Anti-Injunction Act and the narrow paths around it, bankruptcy treatment, and collection against transferees, nominees, and successors.
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