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.

Tax Collection: A Comprehensive Guide to Liens, Levies, Installment Agreements, Offers in Compromise, and Collection Due Process

Tax > IRS Collection, Liens, Levies, and Offers in Compromise | Published 9 December 2024 - Updated 24 December 2025 | UpLaw - uplaw.us

How to use this guide

Every collection engagement begins with the same four determinations: what is assessed, what the lien reaches, what the client can pay, and when the collection period expires. Chapters 1 through 4 cover the first two, Chapters 8 through 11 the third, and Chapter 13 the fourth. Read them in that order the first time.

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