IRS Collection

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IRS Collection

Program originally presented Thursday, April 29, 2021

While our tax system is designed to involve voluntary compliance, not everyone complies voluntarily or is able to pay their taxes when due. Accordingly, Congress has given the Internal Revenue Service (IRS) administrative collection tools that make it an extraordinarily powerful creditor. Congress and the IRS have also given taxpayers some options to pay their taxes, as well as some specific protections before the IRS initiates administrative collection action. This intermediate encore CLE program is designed to provide an overview of the administrative collection process used by the IRS.

Panelists address the following topics among others:

• The tax assessment process, including mechanisms for judicial review of the assessment
• Federal tax liens, including discussion of attachment, priorities, and potential defensive tactics
• Federal tax levies, impact on owner of property, and potential defensive tactics
• Collection due process
• Collection alternatives, including installment agreements, partial pay installment agreements, and offers in compromise based upon doubt as to collection and doubt as to liability
• Audit reconsideration
• Third party collection cases
• COVID-19 collection relief

Panelists:
Molly H. Donohue, Esq.
Staff Attorney, SBSE Division Counsel
Assistant Division Counsel (GL)
IRS Office of the Chief Counsel

Thomas M. Rath, Esq.
Assistant Division Counsel (GL), SBSE Division Counsel
IRS Office of the Chief Counsel

Prof. Christine Speidel, Esq.
Assistant Professor of Law
Director of the Federal Tax Clinic
Villanova University Charles Widger School of Law

James R. Malone, Jr., Esq.
Principal, Post & Schell, P.C.

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