MVLS and Frost Law: From Notice to Negotiation: Mastering IRS Collection Appeals

IRS collection actions—liens, levies, and enforced collection—can have immediate and severe consequences for taxpayers. Yet the Internal Revenue Code and IRS administrative framework provide multiple avenues for challenging those actions through collection appeals. Understanding when and how to invoke those rights is critical for effective representation.

This program provides a practical, practitioner-focused overview of IRS collection appeals, including Collection Due Process (CDP) hearings, the Collection Appeals Program (CAP), and related administrative remedies. The presentation will walk through the lifecycle of a collection case, from initial notice through appeal and resolution, highlighting strategic considerations, common procedural traps, and advocacy opportunities.

Participants will learn how to evaluate which appeal mechanism is available, how to frame issues effectively before Appeals, and how collection appeals intersect with other resolution options such as installment agreements, offers in compromise, currently not collectible status, and innocent spouse relief. The program will also address recent trends and best practices drawn from real-world cases.

Attendees will leave with a clearer roadmap for protecting taxpayer rights, slowing or stopping collection activity, and positioning cases for more favorable outcomes.