Tax Collection Defense

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8.0 Credits

Tax collection issues can be as simple as responding to a bill or as complicated as a bankruptcy reorganization. To represent a client in a tax collection matter, a CPA should have a fundamental understanding of tax collection laws.

Understand the available options for resolving tax collection cases and the procedures available for reaching those resolutions. This course will analyze applicable laws, procedures and potential resolutions, including the law of tax liens and levies and procedures available for resolving a tax collection matter. Also, cover alternative resolutions, including installment agreements, offers in compromise and bankruptcy.


  • Recognize the tax collection functions of the IRS and California tax authorities.
  • Understand the law of tax liens and levies, including attachment to property, perfection and priority over competing interests.
  • Identify the available procedures, including collection due process (CDP), other collection appeals and lien relief alternatives.
  • Determine the options for resolving collection issues, including installment agreement and offer in compromise rules and discharging and resolving taxes in bankruptcy.

Major Topics

  • Assessment and attachment rules—tax assessment procedures and attachment of the assessment lien to property, including community property.
  • Tax liens—perfection and priority rules in general and for specific assets and relief from liens.
  • Tax levies and seizures—taxpayer rights and defenses; third party rights.
  • Dealing with the collection officers and representatives.
  • Collection appeals—collection due process (CDP) and other collection appeals.
  • Collection resolutions—offers in compromise; installment agreements; bankruptcy.
  • Judicial actions: collection due process (CDP); injunctions; and IRS suits.

Designed For

CPAs and attorneys.


Working knowledge of resolving tax bills helpful or professionals who handle tax collection issues with the IRS, FTB, EDD and CDTFA. 

Advanced Preparation