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Taxpayer's Right to Appeal an Adverse
IRS Collection Action

This information is intended as technical information of use to
consultants and individuals doing research.
Most Important Things To Know:-
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When a taxpayer does not agree with decisions of IRS
employees, the taxpayer has the right to an administrative review with the employee's
manager.
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A taxpayer may appeal a Notice of Federal Tax Lien before
or after the IRS files a lien.
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A taxpayer may appeal a denied request to withdraw a
Notice of Federal Tax Lien filing and denied discharges, subordinated and
non-attachments of liens.
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A taxpayer may appeal before or after the IRS places a
levy on a taxpayers' wages, bank account, or other property
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A taxpayer may appeal a seizure of property before or
after the IRS makes a seizure. An appeal after the IRS makes a seizure must be appealed
to the Collection Manager within 10 business days after the Notice of Seizure is
provided to the taxpayer or left at a taxpayer's home or business.
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A taxpayer may appeal a termination of an Installment
Agreement when notified that the IRS intends to terminate the installment agreement.
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A collection action made by telephone can be appealed by
telephone. The taxpayer must state the points of disagreement and a solution to the tax
problem. If the taxpayer cannot reach an agreement with the IRS employee, the taxpayer
must ask to speak to a manager. The manager is required to reply within 24 hours.
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If there is disagreement with a decision of a Revenue
Officer, a taxpayer must appeal to the Revenue Officer's Collection Manager. If a
taxpayer does not resolve a disagreement with the Collection Manager, the taxpayer may
request Appeals consideration by completing Form 9423, Collection Appeal Request, and
list the Collection actions for which there is disagreement. Taxpayer must also include
a solution to resolve the tax problem. Taxpayer's request for an appeal must be received
by the Collection office within 2 days of the Manager conference; otherwise, the
collection action will resume
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When taxpayer appeals his case, the IRS will normally stop
the collection action until the appeal is settled, unless the IRS has reason to believe
that collection of the amount owed is at risk.
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Once the Appeals Officer makes a decision, that decision
is binding on both the taxpayer and the IRS. The Appeals Officer has more discretion to
settle the dispute than either the Revenue Officer or his Group Manager.
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