IRS Collections: Liens, Levies, and Installment Agreements

Categories: IRS CE, IRS Resolution
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About Course

When a taxpayer fails to pay a federal tax liability after notice and demand, the IRS holds sweeping authority to enforce collection — through liens that attach silently to every asset, levies that seize wages and bank accounts without further court order, and installment arrangements that can resolve years of accumulated debt. This 2-hour self-study course gives enrolled agents, CPAs, and tax practitioners the technical framework to intervene at every stage of the collection process.

The course covers all four layers of IRS collection: federal tax lien attachment, priority, and certificate procedures under IRC §§6321–6323; levy authority, exemptions, and release grounds under §§6331–6343; installment agreement types — streamlined, DDIA, PPIA, and formal — including Form 433-A financial analysis under §6159; and Collection Due Process hearing rights, CDP deadlines, and Tax Court review under §§6320–6330.

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What Will You Learn?

  • Explain how a federal tax lien arises under IRC §6321 and identify the moment it attaches to all of a taxpayer's property and rights to property upon assessment, notice, and demand
  • Describe the purpose of the Notice of Federal Tax Lien (NFTL), the requirements for its validity under IRC §6323(f), and how NFTL filing establishes the IRS's priority over subsequent judgment lien creditors and purchasers
  • Apply the four certificate procedures — release, discharge, subordination, and withdrawal — to protect taxpayer and third-party interests in real estate transactions and financial restructuring
  • Identify the statutory prerequisites for levy under IRC §6331, including the 10-day demand requirement and the Collection Due Process notice procedures that must precede a continuing wage levy or bank levy
  • Calculate the exempt portion of wages subject to levy using the IRC §6334(d) formula and identify other property categories that are partially or fully exempt from IRS levy under §6334
  • Distinguish the types of installment agreements — streamlined, DDIA, PPIA, and formal — and apply the financial analysis standards required when submitting Form 433-A for non-streamlined requests
  • Explain the Currently Not Collectible designation and identify the circumstances under which it is appropriate for clients with documented economic hardship
  • Describe the Collection Due Process hearing procedures under IRC §§6320 and 6330, including the deadlines, the scope of permissible challenges, the difference between CDP and Equivalency Hearings, and the Tax Court review path

Course Content

Module 1 – Federal Tax Liens
This module covers federal tax liens under IRC §6321–6323: how liens arise, the NFTL filing process, priority rules, and Certificate of Discharge and Subordination procedures.

  • Federal Tax Liens

Module 2 – Tax Levies
This module examines IRS levy authority under IRC §6331–6343: continuous levies on wages, bank account freezes, third-party restrictions, and procedural safeguards to release or avoid a levy.

Module 3 – Installment Agreements
This module covers the six types of installment agreements — SLIA, DDIA, Streamlined, In-Business Trust Fund, Partial Payment, and Formal — including financial analysis and taxpayer rights under IRC §6159.

Module 4 – CDP Hearings, Collection Appeals, and Practitioner Representation
This module explains Collection Due Process and Collection Appeals Program hearings under IRC §6320/§6330, CDP grounds, CSED tolling, Tax Court review, and practitioner strategies for clients facing IRS collection.

Final Assessment – IRS Collections: Liens, Levies, and Installment Agreements
Comprehensive 10-question final examination covering all four modules: Federal Tax Liens, Tax Levies, Installment Agreements, and CDP Hearings and Appeals.

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