For privacy and confidentiality reasons, we do not disclose client names. The following case study reflects a real scenario handled by our team.

Client Profile

Type: Small Business

Industry: Logistics & Delivery Services

Situation Summary: The business accumulated payroll and income tax liabilities from 2020–2023 and received a Final Notice of Intent to Levy (Letter 1058) and a filed Notice of Federal Tax Lien (NFTL). A bank levy was issued, freezing operating accounts.

The Challenge

The IRS assessed balances totaling approximately $210,000, including trust fund taxes, penalties, and interest. A bank levy froze primary operating funds, interrupting payroll and vendor payments.

The filed NFTL impacted the company’s credit profile, delaying a pending line-of-credit renewal and raising concerns with key vendors.

The case had been assigned to a Revenue Officer (RO), increasing the pace of enforcement. The RO requested a Collection Information Statement (Form 433-B) and immediate payment or a resolution proposal.

Management faced urgent operational risk: inability to meet payroll within days and potential loss of contracts if services were disrupted.

Our Approach

We secured Form 2848 to represent the client and immediately contacted the assigned Revenue Officer to establish representation and request a short-term hold on enforcement while we gathered financials.

We prepared an expedited Collection Information Statement (Form 433-B), including detailed cash flow, accounts receivable, and necessary operating expenses to demonstrate the business’s ability to sustain payments if the levy were released.

We submitted a levy release request supported by documentation of payroll obligations and essential expenses, arguing that continued levy would create undue economic hardship and jeopardize ongoing compliance.

Concurrently, we brought all required filings current, including reconciling payroll tax returns (Forms 941) and ensuring deposit compliance going forward—critical prerequisites for any collection alternative.

We proposed a structured installment agreement based on verified cash flow and negotiated terms with the Revenue Officer. In parallel, we evaluated lien relief options and prepared a request for lien subordination to facilitate financing needed to stabilize operations.

The Resolution

Within days of engagement, the IRS approved a partial release of the bank levy, restoring access to operating funds and allowing the company to meet immediate payroll and vendor commitments.

Within approximately 60–90 days, a formal installment agreement was established, aligning monthly payments with the company’s cash flow and preventing further enforcement actions.

A lien subordination was granted to support the renewal of a working capital facility, improving liquidity and operational stability.

The company returned to full compliance with current deposits and filings, significantly reducing enforcement risk and stabilizing relationships with lenders and vendors.

Key Takeaways

• Immediate engagement with a Revenue Officer can halt or mitigate active enforcement actions.

• Accurate and timely preparation of Form 433-B is critical to securing levy relief and negotiating terms.

• Maintaining current filing and deposit compliance is essential to qualify for collection alternatives.

• Lien subordination can be a practical tool to unlock financing and stabilize operations.