Practice Area
IRS Collections & Enforcement
Representation and options for individuals and businesses facing IRS liens, levies, wage garnishments, and other collection actions.
When a tax balance turns into a collection matter
An unpaid tax bill does not stay quiet for long. When taxes go unpaid, the IRS moves from sending reminders to taking action, and the tools it can use are powerful. It can place a lien on your property, take money directly from a bank account, garnish wages, and reach other assets. For many people, the collection process feels frightening precisely because it seems to move on its own schedule, with escalating notices and little room to breathe.
The reassuring part is that the collection system also contains defined rights, deadlines, and alternatives, and understanding them changes the picture. There is almost always more than one path forward, and the earlier you understand your options, the more of them remain open. Kathryn Meyer spent more than two decades inside the IRS Office of Chief Counsel, and she uses that experience to help clients understand how the IRS approaches collection decisions and how to work toward a resolution that fits their circumstances.
How the collection process usually begins
Collection does not start with a levy. It starts with a series of notices, and each one is a point at which you still have choices. After a balance is assessed, the IRS sends a bill, then a sequence of increasingly firm letters requesting payment. These notices explain the amount owed, the interest and penalties that continue to accrue, and the steps the IRS may take if the balance remains unpaid.
The most important letter in this sequence is the final notice of intent to levy, which also informs you of your right to a hearing. This notice is significant because it starts a clock. It gives you a limited window to request a Collection Due Process hearing, which pauses enforcement and gives you a chance to propose alternatives or dispute the collection action. Letting that window pass narrows your options, so recognizing this notice for what it is can make a meaningful difference.
Tax liens and what they mean
A federal tax lien is the government's legal claim against your property when a tax debt goes unpaid. The lien attaches to what you own, including real estate, and can affect your ability to sell or refinance. When the IRS files a public document called a Notice of Federal Tax Lien, the claim becomes visible to creditors and can complicate financial transactions.
A lien is not the same as a levy. A lien is a claim; a levy is an actual taking. That distinction matters because a lien, while serious, can often be managed. Depending on the situation, it may be possible to seek a discharge that releases the lien from a specific piece of property, a subordination that allows another creditor to move ahead so you can refinance, or a withdrawal of the public notice when certain conditions are met. Resolving the underlying balance, or entering an agreement to pay it, is usually the path that leads to the lien being released. Each of these options has its own requirements, and choosing among them depends on your goals and your finances.
Levies, bank seizures, and wage garnishment
A levy is the IRS taking property to satisfy a tax debt. The most common forms are a bank levy, which reaches the funds in your account, and a wage levy, often called a garnishment, which requires your employer to send part of each paycheck to the IRS until the matter is resolved. The IRS can also levy other assets and receivables in certain circumstances.
Levies can be disruptive, but they are not the end of the road. In many cases a levy can be released, especially when it is causing a genuine economic hardship or when you enter into an agreement to address the balance. The right response depends on the type of levy, the timing, and your overall financial situation. Acting quickly tends to expand what is possible, because some protections depend on requesting relief within a specific period.
The alternatives to simply paying in full
Most people who owe the IRS cannot write a single check for the full amount, and the system recognizes that. Several structured alternatives exist, and the right one depends on how much is owed, your income and expenses, and the value of your assets.
An installment agreement lets you pay the balance over time in monthly amounts. There are different kinds, from straightforward arrangements for smaller balances to agreements that require a review of your finances for larger ones. A well structured installment agreement can stop enforced collection and give you a predictable path forward.
An offer in compromise allows some taxpayers to settle a tax debt for less than the full amount owed. It is not available to everyone, and it is not the quick fix that some advertisements suggest. The IRS evaluates an offer based on what it believes it could reasonably collect from your income and assets over time. When the facts support it, an offer can resolve a balance that would otherwise be unmanageable, but each offer rises or falls on careful preparation and honest financial disclosure.
Currently not collectible status is another option. When paying anything toward the balance would prevent you from meeting basic living expenses, the IRS may agree to pause collection. The debt does not disappear, and interest continues, but enforced collection stops while your situation improves. This can be an important breathing space during a difficult period.
Penalty relief is worth considering as well. A significant part of many tax balances is made up of penalties, and in some situations those penalties can be reduced or removed. Relief may be available when you have a history of compliance, or when circumstances outside your control, such as a serious illness or a natural disaster, kept you from meeting an obligation on time.
Collection Due Process and your right to be heard
The right to a Collection Due Process hearing is one of the most valuable protections in the collection system. When you receive a final notice of intent to levy, or notice of a filed lien, you generally have a limited period to request a hearing before the IRS Office of Appeals. That request pauses enforcement and gives you a neutral setting in which to propose a collection alternative, question the amount, or raise other issues.
These hearings are also significant because, in many cases, a decision that comes out of a Collection Due Process hearing can be reviewed by the United States Tax Court. That means the right to a hearing is not only a chance to resolve the matter within the IRS, but also a gateway to judicial review if the process does not produce a fair result. Preserving that right depends on meeting the deadline, which is why the notice that grants it deserves prompt attention.
The collection clock
The IRS does not have unlimited time to collect. There is a statute of limitations on collection, often measured as roughly ten years from the date a tax is assessed, after which the ability to collect generally ends. This period can be paused or extended by certain events, such as bankruptcy, a pending offer in compromise, or time spent in a Collection Due Process hearing. Understanding where a balance stands in relation to this clock is sometimes an important part of deciding how to proceed. It is a technical area, and the calculation is not always intuitive, but it can shape strategy in meaningful ways.
Special situations for spouses and business owners
Some collection matters involve issues beyond a straightforward balance. A person who filed a joint return may find themselves pursued for tax attributable to a spouse or former spouse. In defined circumstances, innocent spouse relief can separate one person's responsibility from the other's, though the requirements are specific and the facts matter.
Business owners face their own particular exposure. When a business withholds payroll taxes from employees but does not pay them over to the government, the IRS can pursue the individuals it considers responsible through what is called the trust fund recovery penalty. This can reach owners, officers, and others with authority over the finances, and it can turn a business tax problem into a personal one. These matters call for careful attention to who had control and who made decisions, because the answers determine who bears responsibility.
How Kathryn Meyer approaches collection matters
Kathryn Meyer works with clients who have received notice of a lien or levy, who are facing wage garnishment, or who want to resolve a balance before enforcement begins. She also helps those who cannot pay in full and need to understand alternatives such as installment agreements, an offer in compromise, or currently not collectible status.
Her approach begins with understanding your full financial picture and the deadlines that apply, because both drive what is realistic. From there she helps you weigh the available options and pursue the one that fits your goals and resources, handling communication with the IRS along the way. Her years inside the Office of Chief Counsel give her insight into how the IRS evaluates collection decisions and what tends to move a matter toward resolution. No responsible attorney can promise a specific result, but experienced guidance can help you find the path that makes sense for your situation.
Staying on track after a resolution
Resolving a tax balance is only part of the picture. The IRS generally expects a taxpayer who has entered an agreement to stay current on future filings and payments, and falling behind again can undo an arrangement that took real effort to put in place. Part of a durable resolution is a plan for staying compliant going forward, which often means adjusting withholding or estimated payments so that a new balance does not quietly build while an old one is being paid down. A resolution that holds up over time is usually one that accounts for the future as well as the past.
A word about bankruptcy and taxes
Bankruptcy is sometimes raised as a way to deal with tax debt, and in narrow circumstances certain older income tax obligations can be discharged when specific conditions are met. But many tax debts survive bankruptcy, the rules are technical, and the timing interacts with liens and with the collection statute in ways that are easy to get wrong. Bankruptcy is rarely the first option to consider, and it is only one tool among several. Where it may be relevant, understanding how it fits with the other alternatives, rather than viewing it in isolation, is part of thinking through a complete approach to a difficult balance.
Taking the first step
Collection problems rarely improve by waiting, and many of the most useful protections depend on acting within a specific window. If you have received a collection notice, are facing a lien or levy, or simply owe more than you can pay and want to understand your options, a conversation is a reasonable place to begin. There is no obligation in learning where you stand and what paths are open to you.