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Fiscal Year 2023 Statutory Review of Compliance With Notice of Federal Tax Lien Filing Collection Due Process Procedures

Report Information

Date Issued
Report Number
Report Type
Joint Report
Agency Wide
Yes (agency-wide)
Questioned Costs
Funds for Better Use


Issue a reminder to Collection employees to reinforce guidance in Internal Revenue Manual (IRM) 5.12.7 to ensure that NFTLs and CDP lien notices reflect the correct information for the taxpayer.

Review the three cases to determine if the CDP notices were re-sent to the last known addresses or if the taxpayers were otherwise provided their CDP rights; then take corrective action, if needed.

Consider implementing codes that would allow for internal and external review to determine the date of non-ALP levies and seizures.

Conform IRS levy practice to follow the existing IRM which generally prohibits levies during lien CDP hearings.

Revise the IRM procedures to clarify that copies of notices and other written communications should only be provided to representatives for whom taxpayers have expressly designated the IRS to send them.