The United States has the power to place a lien on a taxpayers’ property and rights to property when that taxpayer has unpaid federal taxes.[1] The government is statutorily authorized to bring a civil action to enforce this lien under Internal Revenue Code (IRC) § 7403.[2] While § 7403 generally provides that courts are to adjudicate lien enforcement actions on …
Collection Due Process Hearings Prior to the IRS issuing a levy it must give the taxpayer a final notice of intent to levy. If the IRS files a tax lien, the IRS must give the taxpayer a notice after the tax lien has been filed. The notices give the taxpayer 30-days to request a collection due process (CDP) hearing. If …
A. Introduction In order to protect the revenue, Congress has provided an administrative means of collection on IRS assessments by attaching a lien to the taxpayer’s property. To expand further, this lien (often referred to as the “general” or “statutory” lien) not only attaches to all of the taxpayer’s property, but to all of the taxpayer’s rights to property, whether …
