Attachment Issues: The Federal Tax Lien and Levy Power

A federal tax lien and an IRS levy work in different ways, and knowing which one applies to a case changes the options on the table. This session opens with the lien: how it arises, how the notice of federal tax lien sets its priority against other creditors, and the paths available to release, discharge, subordinate, or withdraw it.

From there, the focus shifts to the levy power. Rebecca Sheppard, Esq., and Peter Haukebo, Esq., walk through the notice requirements that must precede a levy, the categories of property the IRS cannot reach, and the obligations a levy places on banks and employers. They close with the remedies available when the IRS levies property it had no right to touch.

Attendees leave the session able to identify which collection tool is in play, assess a taxpayer's actual exposure, and match the situation to the correct relief provision.