Usually, the federal government’s process for collecting a
contested amount of income tax operates at a slow and deliberate pace:
- After examination of a return, the IRS issues a
notice of deficiency, I.R.C. § 6212(a); - The notice of deficiency puts collection on hold
while the taxpayer has the opportunity to seek review from the Tax Court,
I.R.C. § 6213(a); - Even if the taxpayer does not petition to the
Tax Court to review the deficiency, the IRS cannot utilize its administrative
enforcement tools without providing the taxpayer with the right to a hearing. See
I.R.C. §§ 6320 (due process for liens), 6330 (due process for levies).