Circumstances under which a levy may be released include:
- The liability is satisfied or becomes unenforceable.
- The release will facilitate collection (i.e., the property will be sold and proceeds transferred directly to the IRS).
- The taxpayer enters an installment agreement.
- The levy causes economic hardship to the taxpayer (e.g., Currently Not Collectable status).
- The fair market value of the asset exceeds the liability and release will not hinder collection.1
- 1I.R.C. § 6343(a); I.R.M. 5.11.2.2.1.