The IRS Is Coming
After What You Have.

Most IRS notices are informational or propose an adjustment — they do not require immediate action but should never be ignored. A Final Notice of Intent to Levy (LT11 or Letter 1058) is different: it triggers a 30-day deadline to request a Collection Due Process (CDP) hearing. Missing that deadline forfeits your right to appeal the levy in Tax Court. If you have received a document with the words "final notice" or "notice of intent to levy," contact a tax attorney immediately.

Yes, but it is rare and requires multiple procedural steps. The IRS can file a federal tax lien against your home, which clouds title and prevents sale or refinancing. To actually seize and sell a personal residence, the IRS must obtain court approval — a higher bar than levying a bank account or wages. Retaining a tax attorney early is the most effective way to prevent a lien from becoming a seizure. The MacPherson Group has helped numerous clients protect their homes through lien subordination, discharge, and negotiated resolution.

An Offer in Compromise (OIC) is an agreement between a taxpayer and the IRS to settle a tax debt for less than the full amount owed. The IRS accepts OICs on three grounds: doubt as to collectibility (you cannot pay the full amount), doubt as to liability (the tax was incorrectly assessed), or effective tax administration (paying would create economic hardship or be inequitable). Qualification depends on your income, assets, expenses, and the nature of the debt. The MacPherson Group evaluates OIC eligibility as part of every civil tax engagement — and negotiates the offer calculation so you pay as little as the law allows.

Ignoring IRS notices accelerates the collection process and eliminates your options one by one. The IRS sends a series of notices beginning with a balance-due notice (CP14) and escalating to a Notice of Intent to Levy (CP504) and a Final Notice of Intent to Levy (LT11). Once the final notice period expires, the IRS can levy bank accounts, garnish wages, seize assets, and file tax liens against your property — all without a court order. The later in this sequence you retain counsel, the fewer options remain available and the more it costs to resolve.

Yes. Unlike private creditors, the IRS can garnish wages without a court judgment — its levy authority is administrative, not judicial. It can also levy Social Security benefits (retaining only a small exempt amount), pension distributions, retirement account withdrawals, and contractor payments. The MacPherson Group has successfully released IRS levies on Social Security income, wages, and bank accounts for clients across the country. The key is acting before the levy attaches — or immediately after, to seek a levy release and negotiate an alternative resolution.

Currently Not Collectible (CNC) status is a formal IRS determination that a taxpayer cannot pay their tax debt without being unable to meet basic living expenses. When granted, the IRS suspends all collection activity — levies, garnishments, and seizures stop. Interest and penalties continue to accrue, and the IRS reviews the status periodically as your financial situation changes. CNC is often the right immediate step while a longer-term resolution — such as an OIC or expiration of the collection statute — is being prepared.

The IRS generally has 10 years from the date of assessment to collect a tax debt — this is the Collection Statute Expiration Date (CSED). Certain actions toll (pause) this clock, including filing for bankruptcy, submitting an Offer in Compromise, requesting a CDP hearing, and others. Allowing the CSED to expire is a legitimate and often overlooked resolution strategy in some cases. The MacPherson Group calculates the CSED for every civil tax client and evaluates whether statute expiration should be part of the resolution strategy.

CPAs and enrolled agents can handle routine IRS correspondence and straightforward audits. A tax attorney is necessary when: the IRS is considering criminal referral; you need to litigate before the Tax Court or federal court; the IRS has filed a lien and you need to protect property rights; you need attorney-client privilege — which CPAs and enrolled agents do not have and cannot provide; or the resolution involves legal arguments about the validity of the assessment. For any matter where your home, business, livelihood, or liberty may be at risk, you need an attorney, not a tax preparer.