Is the IRS abusing its collection authority?
It’s certainly not news to say that the Internal Revenue Service has enforcement powers to collect a tax liability. Such tools may include filing a notice of levy or tax lien, wage garnishment or even a sale of property.
Of course, federal law also imposes notice procedures upon the IRS. A taxpayer must generally receive notice of a tax liability before the IRS can pursue any collection activities. That notice serves an important purpose: It allows a taxpayer to administratively contest disputed liabilities. After administrative exhaustion, a taxpayer may even be able to file suit in federal Tax Court or U.S. District Court, depending on the procedural context.