One of the most important rights a taxpayer has during the Internal Revenue Service (“IRS”) administrative collection process is to be notified of their right to a collection due process hearing before the IRS issues a levy. Generally, the opportunity to participate in this hearing is one of the last steps in the IRS collection process before a levy occurs. However, in certain circumstances the IRS may issue a levy before notifying a taxpayer of their right to a collection due process hearing. Tax practitioners should familiarize themselves with those circumstances so that they are not caught by surprise when a pre-notice levy is made against their clients.

Originally published in the Journal of Tax Practice and Procedure, December 2018 – January 2019 edition.