Webinar: Attachment Issues: The Federal Tax Lien and Levy Power by ALFi

ALFI

The federal tax lien arises automatically and reaches nearly everything a taxpayer owns, but what it attaches to, who it beats, and when the IRS can actually seize property are separate questions with separate answers.

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Presenters

Rebecca Sheppard

Rebecca Sheppard is a Partner at Frost Law with extensive experience representing clients before the IRS and state taxing authorities. She advises on audits, appeals, and tax litigation, focusing on employment tax and the Employee Retention Credit. Rebecca is known for her practical, innovative approach to controversy work and her ability to translate complex tax issues into actionable guidance for practitioners. She regularly speaks on tax procedure and controversy topics to professional audiences. She is a member of the Maryland State Bar Association’s Taxation Section Council.

Peter Haukebo

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

About

Program Field of Study: Taxes, Federal Tax Related Matter
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, Attorneys, Small Business Owners
Credits: 1 CPE, 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00029-26-O

This session covers the creation and scope of the statutory lien, the role of the notice of federal tax lien in establishing priority against competing creditors, and the administrative options for releasing, discharging, subordinating, or withdrawing a lien. It then turns to the levy power—the notice requirements that precede it, the property Congress placed beyond its reach, the obligations it imposes on banks and employers, and the remedies available when the IRS levies on property it should not have touched. Attendees will leave able to identify which tool the IRS is using, what the taxpayer's exposure actually is, and which relief provision fits the situation.

Agenda

Explain how the federal tax lien arises, what property it attaches to, and how long it lasts;
Determine when filing a notice of federal tax lien affects priority against competing creditors;
Compare the administrative remedies available to address a filed lien and identify when each applies;
Identify the notice requirements and statutory exemptions that govern levy action; and
Recognize the obligations imposed on third parties served with a levy and the remedies available for a wrongful levy.