IRS Tax Collection Appeals

Before the IRS can levy (garnish) your wages or bank accounts, and at the time the IRS files a Notice of Federal Tax Lien, you have the right to dispute these forms of collection action by filing a form with the IRS within 30 days of the date the IRS send you notice of its collection action. The IRS must send you a “collection due process” (CDP) notice before taking levy action, in order to provide you with an opportunity to propose “less intrusive” means for the IRS to attempt tax collection. It is very important to file this form with the appropriate IRS office because the IRS has been known to levy different types of bank accounts and wages immediately after the 30-day period.

This CDP procedure came about as a result of Congressional action in 1998, in response to taxpayer complaints that the IRS heavy-handedly (some would say oppressively) levied retirement, bank, Social Security, and business-operating accounts, without providing taxpayers enough opportunity to resolve their tax liabilities in a reasonable and equitable manner.

David A. Sprecace has more than 23 years of experience preparing this form and conferring with IRS Appeals Officers on behalf of clients in this situation. Call 303-454-8260 or email Dave at to set up a phone consultation.


Colorado Office
600 17th St #2800s

Denver, CO 80202

Client Reviews

Dave has ridden to our rescue on many occasions. It’s not that I try to get in trouble but Dave is always there to bail me out. Dave went toe-to-toe with the IRS over a several year legal battle. Nothing like having a...

- Russell and Lisa P.

My business partner and I hired Dave to represent us with an IRS tax audit of our company and individual tax returns. There were other family members and other businesses involved, and the IRS initially wanted more than...

- Mark M.

I called Dave to help me file several years of income tax returns. After the returns were filed, Dave filed an Offer in Compromise to get rid of the old taxes. The IRS accepted a small fraction of the original amount...

- Mike W.

When I needed to buy out my business partner, Dave told me of the possible pitfalls with the Operating Agreement, walked me through the entire process, helped me value the company, and make an offer. I was able to keep...

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