The Internal Revenue Service has serious tools available to collect unpaid taxes, as do all of the states. Everyone has heard of installment payment agreements, Offers-in-Compromise, fresh starts and uncollectible status. The tax collection world requires a clear understanding of the precise expectations of the IRS and total transparency. Know the taxpayer’s assets and liabilities and document the numbers.


The Internal Revenue Code provides for an administrative review of lien and levy actions (Collection Due Process Hearings).Once completed, those reviews can be examined (the IRS’s Notice of Determination) by the Tax Court, an excellent tool that can only produce a return to the administrative process, basically a “do over” with instructions, except in limited cases of pure legal issues. See Bankruptcy Tax Litigation for a better tool.