Taxpayers may contest more types of IRS collection action by filing a Collection Appeal. Unlike Due Process Hearings, Collection Appeals can also be filed for Denial or Termination of an Installment Agreement, before a Federal Tax Lien is filed, and after a Levy or Seizure of property. They may also be filed for denied requests to withdraw a Notice of Federal Tax Lien as well as denial of Lien Discharges, Subordinations, and non-attachments. Collection Appeals must be requested within certain prescribed time limits. Collection action will normally be suspended until the IRS Appeals Office makes a determination. Once they make a determination, it is final and binding on both the IRS and the taxpayer. There is no judicial review of Appeals’ decision in a court of law. Let us help you request a Collection Appeal and represent you before the IRS Appeals Office.
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