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IRS Enforced Collection Actions: Challenges and Responses to Federal Tax Liens and Levies

Mitigating the Effects of Tax Liens, Navigating the Levy and Asset Seizure Process

Recording of a 90-minute premium CLE/CPE webinar with Q&A

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Conducted on Tuesday, February 14, 2017

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will provide tax attorneys, CPAs and enrolled agents with a comprehensive and practical guide to navigating the process of responding to and challenging IRS collection actions, both Notice of Intent to Levy and Notice of Federal Tax Lien. The panel will discuss the lien process, detailing the stages of IRS collection activity, and provide useful tools for challenging or delaying lien proceedings. The webinar will also offer guidance on the formal appeals process, including bases for appeal, and useful tools for compiling and submitting the appeal correspondence and documentation.


One of the most frightening events for delinquent taxpayers is receiving an IRS notice indicating that the Service is pursuing an enforced collection action. Because taxpayers often delay in engaging representation in dealing with IRS correspondence, tax counsel often becomes involved only after the time period in which negotiation and resolution can be handled by correspondence and payment plans.

Tax counsel must accordingly have an advanced understanding of the IRS enforced collection process to effectively defend taxpayers who find themselves subject to lien or levy notification.

The key statutory tools available to the IRS in collecting alleged tax deficiencies are lien, levy and asset seizure powers. Each of these actions has a defined course of escalating notice and response requirements. Depending on the nature of the tax due and the stage of the collection process, tax counsel has available defense and mitigation remedies to each collection action.

Knowing what tools are available to challenge IRS enforced collections enables tax counsel to properly respond to IRS actions. Listen as our experienced panel provides a thorough, “beyond-the-basics” guide to effectively navigating the IRS collection process once asset attachment or seizure is on the table as an option for collecting delinquent tax.



  1. IRS enforced collection process
    1. Lien process
    2. Levy
    3. Asset seizures
  2. Challenging liens
    1. Claiming IRS issued lien in error
    2. Appealing a lien filing under IRS Section 6320
    3. Obtaining partial or full discharge of lien
  3. Challenging and defending against levy action
  4. Assets exempt from levy


The panel will review these and other key issues:

  • What is the correspondence chain leading up to enforced collection action by the IRS?
  • What are the remedies and relief provisions to challenge or mitigate a tax lien?
  • What are the bases of challenging tax levies and asset seizures?
  • How to obtain full or partial discharge of tax liens


Venar R. Ayar, Esq.
Venar R. Ayar, Esq.

Founder and Tax Attorney
Ayar Law

Mr. Ayar focuses his legal practice on IRS and Michigan tax resolution for both businesses and individuals. He...  |  Read More

Erica Good Pless, J.D., LL.M.
Erica Good Pless, J.D., LL.M.

The Pless Law Firm

Ms. Pless practices primarily in the area of federal tax controversies. She represents individuals and businesses...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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