Can a Levy be appealed?
Yes. In most cases, our clients retain us to request a Collection Due Process hearing with the Office of Appeals. Grounds for appeals include: The taxpayer has paid all taxes owed before the IRS sent the levy notice The IRS assessed the tax and sent the levy notice when the taxpayer was in bankruptcy, and subject to the automatic stay during bankruptcy The IRS made a procedural error in an assessment The time to collect the tax (called the statute of limitations) expired before the IRS sent the levy notice The taxpayer did not have an opportunity to dispute the assessed liability The taxpayer wants to discuss collection options The taxpayer wants to make a spousal defense.
