The collection of tax is a crucial function of the government, and it spares nothing in its efforts to collect tax. Moreover, Congress has given the IRS tremendous authority to collect tax, including significant lien powers and the right to levy and sell a taxpayer’s property to satisfy a debt. The enforcement of these powers can be crippling to a business’s ongoing operations. Fortunately, and necessarily, the Internal Revenue Code and tax regulations balance the government’s collection efforts with statutory taxpayer protections and payment alternatives. For instance, relief from IRS liens (through discharge, release, subordination, etc.) is available under certain circumstances. This relief can be crucial, for instance, where the tax debtor is seeking to sell property or inventory, but the price is being driven down or the sale is otherwise being hampered by the presence of the IRS lien.
Taxpayers facing collection actions can also seek to settle their tax liabilities through installment payment plans or offers in compromise. An offer in compromise requires the taxpayer to submit information regarding his or her income, assets, and liabilities to allow the IRS to determine how much can reasonably be expected to be paid during the collections period. In situations where a taxpayer simply cannot afford to pay the liability in a reasonable amount of time, offers in compromise can be an effective way to settle a tax liability for less than its total amount. Offers in compromise also have the effect of suspending collection action and allowing the taxpayer to regroup while it negotiates with the IRS.
Additionally, a tax debtor, upon receipt of notice that the IRS has filed a tax lien or intends to levy property, has the right to seek Appeals Office review of the propriety of the collection action by filing what is known as Collection Due Process appeal. In that context, the appeals office will review the proposed collection action to ensure that procedural requirements were followed and allow the taxpayer to propose a collection alternative, such as an installment agreement or offer in compromise.
If the taxpayer is dissatisfied with the Appeals Office’s determination, it can petition the Tax Court for review. Note that the ability to challenge the substantive underlying liability is greatly circumscribed in the CDP context; generally, only if the taxpayer did not receive a notice of deficiency (and therefore have the right to seek Tax Court review) will review of the substantive liability during a CDP hearing be proper.
Attorney Crystal L. Johnson has extensive experience with all stages of tax controversy and dispute resolution, from the beginning of an audit to crafting a beneficial offer in compromise, to litigating in Tax Court and District Court, and arguing appeals thereafter. From her experience, the earlier a taxpayer engages the assistance of counsel, the better the outcome.