Collection Appeals

IRS has established a procedure whereby taxpayers may appeal decisions of IRS employees to file a lien, levy, or seize assets of the taxpayer. This procedure has now been codified into the IRC by the RRA of 1998. Additionally, the  RRA of 1998 provides for appeal to the Appellate Division prior to levy or seizure in many instances, as well as binding and non-binding arbitration of many issues following any decision of the Appellate Division. Finally, the taxpayer will now have jurisdiction to file a suit in the US Tax Court or the U.S. District Court on many decisions of IRS' Appellate Division.