Tax Collections

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At Milikowsky Tax Law, we aggressively fight to defend our clients’ legal rights against tax collections efforts from the IRS and state tax agencies, helping them maintain control of personal and business assets. If you have a severely high tax balance, our San Diego tax lawyers are here to help you understand your options, ward off penalties, and regain financial stability. Our goal is to exceed your expectations in the value we provide.


When your business owes significant taxes, the IRS may refer your case to a local revenue officer, who will contact your office to review financial records. If the officer concludes that your company is able to pay its tax liability, the revenue officer can employ tax collections methods. These could include levying the company’s bank accounts, seizing company assets, and filing liens to protect the government’s interest.

When a business owes either state sales tax or federal / state payroll taxes, individuals can be held personally liable for a portion of the business’ tax liability. If an individual is held responsible for payment, the IRS or California state tax agency can then begin a collection action against the individual. Delinquent payroll taxes can be collected for up to 10 years from the date the tax is assessed. Our San Diego tax collection lawyer can assist.


Upon the conclusion of an audit by the Internal Revenue Service (IRS), the IRS Revenue Agent will issue a 90 Day Letter, also known as the Notice of Deficiency (NOD). The purpose of the NOD is to give a taxpayer a means to contest the IRS proposed assessment before collection proceedings begin. Once an NOD is issued, the taxpayer must file a petition with the U.S. Tax Court within 90 days of the date appearing to preserve their right to contest the deficiency. If the taxpayer does not file a U.S. Tax Court Petition before the 90 day time period expires, the IRS will assess the tax and the tax becomes debt owed to the U.S. government.

The IRS has 60 days after it makes an assessment to give the taxpayer the notice and demand for payment. If the taxpayer fails to pay taxes after a demand for payment is made, the tax becomes a lien on all taxpayer’s real and personal property until the liability is paid.


There are several methods that the IRS may use in tax collections for back taxes owed by a taxpayer or a company that has been singled out for unpaid taxes. These potentially devastating techniques include:

  • Filing a public tax lien against you
  • Pursuing constructive dividends
  • Garnishing wages
  • Levying, or freezing, bank accounts
  • Seizing a company’s accounts receivable from debtor clients
  • Issuing trust fund recovery penalties
  • Making attempts to close a company’s doors

Whatever problem you face with the IRS, we are prepared to fight for you. We can put our negotiation skills to work in an attempt to lower the taxes and penalties you face. From securing an offer in compromise to setting up an installment agreement, we will find a solution that is right for your situation. Bankruptcy may also be a viable option to consider. Other options that an individual can pursue include filing for innocent spouse relief or proving that you are eligible for “currently not collectible” status.

If your company has serious tax issues, such as a dangerously high tax balance, we are here to help you keep your doors open. Call our San Diego tax law firm for the legal support you deserve!