Strategic Legal Help for IRS Collection Disputes
Are you facing tax problems as a result of an IRS audit? Have you been assessed taxes or penalties and need to negotiate proactively with the IRS to resolve the issue? The time to act is now, before the IRS takes serious action by garnishing your wages, seizing your assets, or filing liens against your property.
If you are a business owner, the IRS may even come after you personally for any unpaid payroll taxes due from your business. Don't wait until it's too late to take action! At The Wilson Firm, we specialize in resolving tax collection issues such as liens, levies, seizures, and wage garnishments.
How Our Lawyers Can Help in IRS Collection Matters
Our experienced tax attorneys can defend against and challenge unreasonable assessments and collection actions, including filing tax liens against your home, levying your bank account, or garnishing your wages. We can also help with tax liabilities resulting from foreclosure, loan modification, and credit card negotiations, as well as innocent or injured spouse cases.
If negotiations with the IRS are not fruitful, our attorneys can challenge the process administratively through IRS Appeals, with the U.S. District Courts, or the U.S. Tax Court. We have successfully negotiated with the IRS to lower penalties, stopped collection actions, and given clients the time needed to get their financial affairs in order.
Types of IRS Collection Matters We Handle
We represent clients in a variety of IRS collection disputes, including but not limited to:
Liens, levies, seizures and wage garnishments
If you do not file a tax return or respond to IRS notices, the IRS may file a substitute return for you as a single filer with no deductions, leading to inflated liabilities. This can trigger aggressive actions like filing a tax lien against your home, levying your bank account, or garnishing your wages. Our tax lawyers work to defend against and challenge these unreasonable assessments and collection actions.
Tax Liabilities from Foreclosure, Loan Modification, and Credit Card Negotiations
Debt forgiveness from banks or credit card companies can create significant tax liabilities, often reported on Form 1099-C. The forgiven amount is typically treated as taxable income by the IRS. Our lawyers defend these determinations, explore exclusions (like insolvency), and minimize the tax due.
Innocent or Injured Spouse Relief
If we can prove you qualify as an innocent or injured spouse—meaning you were unaware of your spouse's tax errors or underreporting—you may be relieved of joint liability for those obligations.
Collection Due Process (CDP) Hearings
When negotiations stall, our attorneys request CDP hearings to challenge proposed collections, potentially halting actions while your case is reviewed.
Levy and Lien Strategies: Protecting Your Assets
At The Wilson Firm, we employ proven strategies to halt IRS levies and liens, preventing asset seizures and credit damage. A tax lien is a legal claim against your property to secure the debt, while a levy is the actual seizure of assets like wages or bank funds. Our approach emphasizes proactivity—responding early to notices like CP501 or CP504—to avoid escalation. Below, we outline key strategies tailored to liens and levies.
Strategies for Resolving IRS Tax Liens
An IRS lien attaches to all your property and rights to property, impacting your ability to sell assets or secure loans. We help clients pursue these resolution options:
- Pay the Debt in Full: The fastest way to remove a lien is full payment, after which the IRS releases it within 30 days.
- Installment Agreement or Offer in Compromise (OIC): Enter a payment plan or settle for less than owed, then request lien withdrawal if it aids collection (e.g., enabling refinancing). Eligibility requires demonstrating compliance and financial need; we prepare and submit Form 12277 for withdrawal.
- Discharge of Specific Property: If the property's value exceeds the debt but isn't needed for collection, request discharge via Form 14135 to free it for sale.
- Subordination: Allow a new lender priority over the IRS lien to secure financing, using Form 14134; ideal for home equity loans.
- Prevention and Early Intervention: File returns on time and set up payments proactively to avoid liens altogether—our team monitors notices to negotiate before filing.
Strategies for Stopping IRS Levies
Levies seize assets immediately, but you have rights to appeal and seek release. We act swiftly to protect your income and property:
- Request a Levy Release for Hardship: Demonstrate economic hardship (e.g., inability to pay basic living expenses) via financial statements; the IRS reviews case-by-case and may release if it causes undue burden.
- Collection Due Process (CDP) Hearing: If you receive a levy notice, request a hearing within 30 days using Form 12153 to challenge the levy, propose alternatives, or raise spousal defenses—often halting actions during review.
- Negotiate Payment Alternatives: Secure an installment agreement, OIC, or "currently not collectible" status to stop levies; we conduct financial analyses to build compelling cases.
- Innocent Spouse Relief: If applicable, file Form 8857 to shift liability, preventing levies on your separate assets.
- Proactive Response: Never ignore notices—early attorney involvement can prevent levies from targeting wages, bank accounts, or retirement funds.
With our expertise, we've helped clients release levies on garnished wages and withdraw liens to restore credit and financial flexibility. In 2025, the IRS's People First Initiative continues to emphasize case-by-case hardship reviews, giving more opportunities for relief.
Get Help Resolving Your IRS Collection Matter Today
If you or your business are involved in an IRS collection dispute, don't hesitate to reach out to us. The sooner we get involved, the more options exist for a positive resolution. Contact The Wilson Firm's experienced tax lawyers today.
Frequently Asked Questions
A tax lien is a legal claim the IRS places on your property to secure the debt, alerting creditors and affecting your credit without immediate seizure. A levy, however, is the actual enforcement action where the IRS seizes assets like wages, bank accounts, or property to collect the debt. At The Wilson Firm, we help distinguish and address both to protect your assets.
You can request a release for economic hardship, enter a payment agreement, or file for a Collection Due Process hearing within 30 days of the notice. Our attorneys act quickly to negotiate alternatives like installment plans or offers in compromise, often halting levies before they deplete your funds.
An Offer in Compromise (OIC) allows you to settle tax debt for less than owed if you prove you can't pay the full amount. Qualification depends on income, expenses, and asset equity; we prepare Form 656, conduct financial analyses, and maximize approval chances based on IRS guidelines.
Typically, you have 30 days from receiving a Final Notice of Intent to Levy (e.g., Letter 1058) to request a hearing or propose alternatives. Ignoring it can lead to immediate action—contact us right away to preserve your rights and explore resolutions.
Yes, the IRS can levy real estate or retirement accounts after proper notices, but exemptions and protections apply (e.g., homestead exemptions in Texas). We challenge wrongful levies, seek releases, and negotiate to safeguard essential assets like your primary residence.
