Liens, Levies and When to Call a Lawyer

Tax attorneys Abbey Garber and Brock Whalen will speak at the 2026 Advanced Estate Planning and Tax Institute Summit, hosted by the Texas Society of Certified Public Accountants (TXCPA). Abbey and Brock will discuss the federal tax collection process, including the sequence of IRS notices that typically precedes enforcement actions and tools such as federal tax liens and levies that the agency uses to collect outstanding tax liabilities. They will address recent developments involving collection, the Internal Revenue Manual, Collection Appeals Program, Collection Due Process, penalty relief and passport restrictions. The session will also provide practical guidance for tax professionals assisting clients facing IRS enforcement, ranging from how to identify procedural errors or respond effectively to IRS notices to whether to pursue alternative payment arrangements and other resolution options. Attendees will gain a clearer understanding of the federal tax collection process alongside strategies for advocating on behalf of taxpayers.