Fiscal Year 2019 Review of Compliance With Legal Guidelines When Conducting Seizures of Taxpayers' Property

The Director, Field Collection, should require the Advisory function to determine if there is an active collection case when nonjudicial foreclosure notices are received and, if there is, to properly notify the assigned Collection function employee by providing a copy of the foreclosure notice, as required by the IRM.

The Director, Collection Policy, Small Business/Self-Employed Division, should update the IRM to provide guidance to revenue officers and the PALS employees on the appropriate practice of accepting keys prior to seizure, including what is required to properly secure the keys when they are accepted.

The Director, Collection Policy, Small Business/Self-Employed Division, should develop a procedure which addresses the situation in which the taxpayer is already experiencing an economic hardship, but possesses property (real or personal property) where there may be some equity the taxpayer may need to access for basic living expenses.