THE FOLLOWING ANALYSIS IS TAKEN FROM THE INTERNAL REVENUE
SERVICE RESTRUCTURING AND REFORM ACT OF 1998 STARTING AT § 6320(b):

If you requested a hearing, was your hearing held by the Internal Revenue Service Office of Appeals?
Yes: No:
If you were given a hearing, was your hearing conducted by an officer or employee who had no prior involvement with respect to the unpaid tax?
Yes: No:
If you hearing was conducted by an officer or employee who did have prior involvement respecting the collection of your alleged unpaid taxes, were you told that you did not have to waive the requirement that an impartial officer conduct your hearing?
Yes: No:
If you had a hearing, do you know if the appeals officer at the hearing obtained verification from the Secretary that the requirements of any applicable law or administrative procedure had been met with respect to your alleged taxes?
Yes: No:
(If you checked "no" you will need a Freedom of Information Act request (FOIA) to determine if this was done. That has not been prepared at this time. Click here to receive an email when that FOIA is ready for use.)
If you had a hearing, were you allowed to raise any relevant issue relating to the unpaid tax, including:
Appropriate spousal defenses;
Yes: No:
Challenges to the appropriateness of the collection action;
Yes: No:
Offers of collection alternatives, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-compromise;
Yes: No:
Challenges to the existence or amount of the underlying tax liability for any tax period if you did not receive any statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability.
Yes: No:
When the appeals officer made his determination did he take into consideration:
The verification from the Secretary that the requirements of any applicable law or administrative procedure had been met with respect to your alleged taxes?
Yes: No:
Appropriate spousal defenses;
Yes: No:
Challenges to the appropriateness of the collection action;
Yes: No:
Offers of collection alternatives, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-compromise;
Yes: No:
Challenges to the existence or amount of the underlying tax liability for any tax period if you did not receive any statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability.

Yes: No:

Whether any proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of the person that any collection action be no more intrusive than necessary.
Yes: No:
When the appeals officer made his determination did he tell you about:
Your right to appeal within 30 days of a determination by him to the Tax Court or to a district court of the United States?
Yes: No:
Your right to subsequent hearings regarding collection actions taken or proposed with respect to the appeals officer's determination; or a change in your circumstances with which affected such determination.
Yes: No:
Did the IRS suspend collection activities from the time you requested a hearing and for the period during which your hearing and appeals were pending? (This does not apply if the underlying tax liability is not at issue in the appeal and the court determines that the Secretary has shown good cause not to suspend the levy.)
Yes: No:
If the IRS suspended collection activities during the period in which your hearing and appeals were pending, did they continue that suspension for a full 90 days after the final determination resulting from the hearing?
Yes: No:
If the IRS did not suspend collection activities while your hearing was pending, did the Secretary show that the underlying tax liability was not at issue in the appeal and did the court determine that the Secretary had shown good cause not to suspend the levy?
Yes: No:
DATE OF HEARING IF ANY:
COMMENTS:

1. Save This Form to your Hard Drive

2. IF YOU ANSWERED "NO" TO ANY OF THE QUESTIONS ABOVE the U.S. Supreme Court said in Thatcher v. Powell, 19 U.S. (6 Wheat.) 119 (1821) that no public officer can take any action affecting your property "…unless authorized so to do by express law, …and that the person invested with such a power, must pursue with precision the course prescribed by law, or his act is invalid…" if you answered "no" to any of the questions above, the IRS is probably going to have to remove the lien and will probably do so based upon a properly worded letter sent to the proper motivated official with the authority to order the removal of your lien according to statute. Go here to learn how to do that.