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Due Process requires that the IRS proceed through several different stages before the IRS is permitted to seize a taxpayer's property. Unless the IRS complies with these procedural requirements, its collection efforts may be deemed unreasonable or illegal and therefore void. These stages can be broken down into three stages: (1) assessment of the tax, (2) notice to the taxpayer and (3) collection due process. The colletion due process rules are contained within § 6320, for liens and §6330, for levies. These provisions allow a taxpayer to appeal the levy or lien within the IRS, then if the IRS denise the appeal, the sections grant a taxpayer the right of appeal to the Tax Court.
