Enforcement Defense

Proven IRS Defense Strategies for Serious Enforcement Actions

Experienced tax attorneys to resolve serious IRS tax issues.

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Facing IRS Enforcement? Know Your Rights and Options.

Whether you’ve received an audit notice, a final warning before collection, or a bank levy, the consequences can be serious.
Our tax attorneys specialize in protecting taxpayers from aggressive IRS tactics, ensuring you have the best possible defense.

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We group the IRS activities in three categories.

The IRS uses different enforcement actions depending on the stage and severity of your tax situation. By categorizing these IRS activities into three distinct groups, we quickly pinpoint where you stand in the enforcement process. This framework helps our experienced team respond effectively, addressing your immediate risks and planning strategically to resolve your tax issues.

Actions that create or notice taxpayer liability

Before the IRS collects, they determine how much they believe you owe. If you receive one of the folling notices, it means the IRS is assessing or questioning your liability.

  • Audit
    The IRS reviews your tax return for potential errors or discrepencies.
  • Notice of deficiency
    A formal statement that you owe additional taxes based on their findings.
  • Summons
    A demand for records, testimony or documentation
  • Various IRS Lettters (CP12, CP2401, etc.)
    These notifications may request additional information or adjustments to your tax
    return.

Escalated Collection Actions

Once the IRS determines a tax debt, they may attempt to collect using remote or automated systems. If you receive a notice you should contact the IRS for information

  • Third Party Collectors
    The IRS may assign your case to private collection agencies.
  • Automated Collection System (ACS)
    The IRS uses automated notices and phone calls to demand payment and escalate enforcement.

At this stage ignoring notices can escalate the problem. We help taxpayers negotiate manageable resolutions before the IRS moves forward with aggressive collections.

Serious Enforcement & Collections Actions

If the tax debt remains unresolved, the IRS can take serious actions.

  • Notice of Intent to Levy (NOITL) – A warning that assets will be seized.
  • Levy Actions – Bank Levy, Garnishment, Asset Seizure etc
  • Tax Lien – A public claim against your property. Impacting credit and ownership.
  • Revenue Officer (RO) – IRS agents personally investigate and collect on tax debts.
  • Passport Revocation – Preventing travel for tax payers with significant unpaid tax debt.
  • Tax Court Filing – IRS may take legal action to enforce collections.
  • Lock Letters – Restricting changes to taxpayer accounts due to fraud concerns.

How Our Attorneys Defend Against IRS Enforcement

Our team works quickly to halt aggressive IRS actions and protect your rights. We can:

  • Challenge incorrect tax liabilities before they escalate.
  • Negotiate settlements, payment plans, or hardship status.
  • Prevent levies, liens, and passport revocations.
  • Represent you in IRS appeals and tax court.
We Fix IRS Tax Problems

7 IRS Enforcement Areas We Can Help With

If you’ve received a notice, had a levy issued, or been contacted by a Revenue Officer, you’re in active IRS enforcement. We step in quickly to protect your income, assets, and legal rights — and work to stop the IRS before things escalate.

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This notice is one of the final steps before the IRS can begin seizing your wages, bank accounts, or property. We respond immediately by filing an appeal, opening negotiation, and creating legal barriers that delay or stop collection. Early action is critical, and we handle every part of the process for you.

When the IRS starts taking money directly from your paycheck, it often continues until the full debt is paid — unless you intervene. We work to remove garnishments fast, often within days, while addressing the underlying debt with a strategy that protects your income and gets you back on stable ground.

The IRS can freeze your bank accounts and seize assets with little notice. If this has happened — or you’ve received a warning — we act quickly to request a release, negotiate alternatives, and prevent future levies. We also help you avoid financial and legal missteps that could make the situation worse.

A federal tax lien can damage your credit, block refinancing, and follow you for years. We help you understand the status of any filed liens, challenge improper filings, and pursue options like subordination, discharge, or full withdrawal — all based on what the IRS will accept in your case.

If a Revenue Officer has been assigned to your case, the IRS considers you a high-priority collection target. These agents can show up in person, demand records, or initiate aggressive enforcement. We take over all communication, represent you directly, and work to resolve the issue before it escalates into levies or legal action.

Owing over $60,000 in tax debt can result in the IRS certifying your case to the State Department, leading to passport denial or revocation. We move quickly to challenge the certification or resolve the balance — helping you avoid travel restrictions or immigration complications.

If you’ve received a summons — whether for documents, testimony, or a third-party review — the IRS is actively gathering evidence. We provide legal representation at every stage, ensure your rights are protected, and respond strategically to avoid deepening your exposure.

We have a personalized approach to fixing your tax issue.

Our attorneys get all the facts and then agree on a plan going forward to get you back on track.

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Speak with one of our senior tax lawyers today who will assess your case, answer your questions and explain the different options available to you that give you the best possible outcomes.

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