IRS LIENS & LEVIES
Once a tax is assessed and unpaid, the matter leaves the examination side of the Service entirely and enters collection — a different function, different personnel, and a different set of rights.
They can take the account before they take your call.
A final notice starts thirty days. Inside that window a judge can still review this. Outside it, no one can.
Scheduling does not create an attorney-client relationship. No such relationship exists until the firm has run a conflicts check and both sides have signed a written engagement agreement.
Inside thirty days you keep the judge. Outside them you keep the hearing only.
THE FEDERAL TAX LIEN
A lien arises by operation of law once tax is assessed, demand is made, and payment is not made. Filing a Notice of Federal Tax Lien makes it public and attaches to essentially everything the taxpayer owns. It clouds title on every property held and complicates any sale or refinancing. Relief exists in several forms — withdrawal, release, discharge of specific property, and subordination — each with its own requirements. Discharge and subordination are the tools that let a transaction close.
LEVIES AND GARNISHMENT
A levy takes property. A bank levy reaches the account; a wage levy attaches to pay and continues until released. Both are generally preceded by a final notice carrying the right to a Collection Due Process hearing.
That notice starts a thirty-day clock. Requesting a CDP hearing within it suspends collection and preserves Tax Court review of the determination. Requesting one after it produces an equivalent hearing — similar in substance, but without the judicial review behind it. The difference between those two outcomes is the calendar.
WHAT THE FIRM DOES
Files the CDP request
inside the thirty days where possible, and represents the taxpayer at the hearing.
Moves to release the levy
where it is causing demonstrable economic hardship.
Clears the lien for a closing
withdrawal, discharge, or subordination, depending on what the transaction needs.
Reopens the liability itself
where the taxpayer never had a genuine opportunity to dispute it.
PROPERTY OWNERS
A federal lien is a real estate problem as much as a tax problem. The firm’s real estate practice means the transaction and the lien are handled by the same firm rather than coordinated between two.
The detailed procedure is set out in Collection. Alternatives to paying in full are described on the tax debt resolution page.
The difference between keeping judicial review and losing it is the calendar.
HOW AN ENGAGEMENT BEGINS
Book a free consultation
Thirty minutes, no charge. Bring the notice — we read it together on that call.
The deadline is identified
Which notice it is, what it asserts, and which forums are still open behind it.
Conflicts check and written engagement
Scope and fee agreed in writing before any work begins.
HOW A CONTROVERSY RESOLVES
The firm takes over
Correspondence with the Service runs through the firm. You stop answering.
The position is built and pressed
Records, authority, and the argument — pressed at the earliest stage that will take it, because that is the cheapest place to win.
Resolution
Closed at examination, settled at Appeals on the hazards, or tried. The firm does not hand the file to anyone to reach the last of those.
If you have received a final notice of intent to levy, the thirty days are running. Contact the firm through the contact page or call (561) 529-5873. Representative engagements are described on the Experience page.