The taxpayer generally wants to delay or defeat the collection process. Potential strategies may include showing that the lien or levy is invalid (e.g., the taxpayer did not receive the required notices), avoiding or suspending the levy, or convincing the IRS to pursue alternatives to collection.

IRS seizure of income and assets may cause a taxpayer to default on other debt, suffer eviction or foreclosure, lose a business or the means to make a living, or find it impossible to pay basic expenses. If a taxpayer seeks your help after a levy is already in place, you should act quickly to resolve the seizure or levy.

The Taxpayer Advocate may issue Taxpayer Assistance Orders (TAO) to stop collection activity. A TAO may be issued if the taxpayer is suffering or about to suffer a significant hardship due to IRS action or inaction or for circumstances set forth in IRS regulations.1

TAOs are most often issued when an actual or threatened seizure of a tax refund, bank account, pension plan, car, or wages will leave a taxpayer without enough money for basic necessities or when the seizure will cause the taxpayer to lose a primary home (including through eviction), a car necessary for work, or access to medical care or education. A Form 911 is used to apply for a TAO. The Louisiana Taxpayer Advocate can be reached at 504-558-3001 (phone) and 504-558-3348 (fax).2 If the levy has not yet started, the attorney should request Currently Not Collectable (CNC) status for the taxpayer before the deadlines to respond.3 This will stop most collection actions.

• 1I.R.C. § 7811(a).
• 2For more information on TAOs, see IRS Publication 1546; I.R.M. 13.1.7.2; 26 C.F.R. § 301.7811.
• 3For discussion of CNC status, see Section 6.6.2.