If you’ve received a notice from the IRS about a lien or levy on your property or bank accounts, you’re not alone. Many individuals and business owners across Temecula, San Diego, Riverside, San Bernardino, and throughout California find themselves facing these stressful collection actions. Understanding the difference between tax liens and tax levies is the first step toward resolving the issue. The next step? Getting experienced legal help.

At The Law Office of Pietro Canestrelli, A.P.C., we help clients across California resolve serious tax problems and protect their financial future. This guide explains the basics of IRS liens and levies, what to expect, and how a tax attorney can make a significant difference in your case.

Recent IRS Enforcement Trends: A Warning for 2025

The IRS is ramping up its enforcement efforts, with a sharp projected increase in federal tax lien filings in 2025. This resurgence follows a slowdown during the COVID-19 pandemic and is fueled by three key developments:

Key Factors Behind the Rise in Liens

• Post-pandemic enforcement revival: After years of reduced collection activity, the IRS is resuming enforcement with renewed intensity.
• Artificial Intelligence (AI) deployment: The IRS now uses AI tools to identify high-risk, noncompliant taxpayers—especially those with debts over $25,000. This technology has led to a surge in lien filings.
• Inflation Reduction Act (IRA) funding: The 2022 IRA allocated billions to modernize IRS enforcement, enabling hiring boosts and enhanced technology that support aggressive collection measures.

Targets of Increased Enforcement

• High-income individuals: In 2024, the IRS launched initiatives targeting wealthy taxpayers with unpaid liabilities, recovering over $1 billion in delinquent taxes.
• Delinquent businesses: Partnerships and pass-through entities are under renewed scrutiny due to historically low audit rates.
• Abusive tax schemes: The IRS is cracking down on improper Employee Retention Credit (ERC) claims and abusive transactions involving partnerships and corporate jets.

Notable Developments

• Senator Jim Justice case: In October 2025, the IRS filed over $8 million in liens against U.S. Senator Jim Justice and his wife.
• Erroneous penalty notices: In September 2025, some taxpayers received incorrect notices threatening asset seizure. The IRS confirmed a computer error and began correcting affected accounts.

Implication for Taxpayers:

If you owe back taxes, the risk of enforced collection is higher than ever. AI-driven targeting and increased funding mean the IRS is acting faster and more efficiently. Visit our Tax Relief page to learn how to protect your rights.

What Is a Tax Lien?

A tax lien is a legal claim by the government against your property when you fail to pay a tax debt. It doesn’t mean immediate seizure, but it does mean the IRS has staked a claim on your assets, which can impact your credit and ability to sell property.

Key Points About Tax Liens:

• Public record: A federal tax lien becomes public and can affect your creditworthiness.
• Attaches to all property: This includes real estate, personal property, and financial assets.
• Persists until paid: The lien stays in place until the debt is fully satisfied or discharged.

For more on how liens work and your options, visit our Liens, Levies & Garnishments page.

What Is a Tax Levy?

A tax levy is the actual seizure of your property to satisfy a tax debt. This can include garnishing your wages, taking money from your bank account, or even seizing and selling your real estate or other assets.

Common Forms of Levies:

• Bank account levies: Funds are frozen and then transferred to the IRS.
• Wage garnishment: A portion of your paycheck is redirected to the IRS.
• Asset seizure: The IRS may take vehicles, business assets, or even homes in extreme cases.

Levies are often preceded by multiple IRS notices. If you received a Final Notice of Intent to Levy, you must act quickly to protect your rights.

Liens vs. Levies: What’s the Difference?

• A lien is a claim; a levy is a seizure.
• Liens are passive but damaging to credit; levies are active and can drain accounts.
• Both are collection tools used by the IRS to recover unpaid taxes.

Understanding the difference can help you prioritize and respond effectively. Learn more about proactive steps on our Tax Relief page.

What Triggers a Lien or Levy?

The IRS typically follows a set procedure before initiating liens or levies:

1. Assessment of tax liability
2. Notice and Demand for Payment
3. Failure to respond or pay
4. Notice of Federal Tax Lien filed or Final Notice of Intent to Levy sent

If you’re unsure where you stand, it’s best to speak with a qualified IRS representation attorney who can request your tax transcripts and help interpret your IRS status.

How a Tax Attorney Can Help

Working with a tax attorney can mean the difference between losing property and negotiating a manageable resolution.

Services a Tax Attorney Provides:

• Preventing levies before they occur
• Requesting Collection Due Process hearings
• Negotiating installment agreements
• Submitting Offers in Compromise
• Innocent spouse relief
• Appealing wrongful levies
• Advising on bankruptcy implications

Attorneys are particularly valuable if you’re dealing with large tax debt, multiple years of noncompliance, or complex business and personal finances.

What to Do If You Receive a Levy Notice

1. Don’t ignore it: Delaying action can result in frozen accounts or garnished wages.
2. Call a tax attorney immediately: Timing is critical; you often have just 30 days to request a hearing.
3. Gather financial documents: Tax returns, notices, bank statements, and hardship information are key.
4. Explore resolution options: You may qualify for back tax representation or other relief programs.

Frequently Asked Questions

Can a tax lien be removed?

Yes, through full payment, discharge, withdrawal, or subordination, depending on your situation.

Can I stop a levy after it has started?

Possibly. Quick legal action can result in a release or modification, especially if the levy causes financial hardship.

Will bankruptcy remove a tax lien?

Not necessarily. Tax liens often survive bankruptcy and still attach to property. Consult a tax attorney to explore your options.

Can I negotiate with the IRS myself?

Yes, but an experienced attorney can often get better results, avoid missteps, and handle complex filings.

Serving All of Southern California and Beyond

The Law Office of Pietro Canestrelli, A.P.C. represents clients in Temecula, San Diego, Riverside, San Bernardino, and across California. Whether you’re facing IRS liens, levies, garnishments, or audits, we provide strategic legal solutions tailored to your unique situation.

Contact us today to schedule a confidential consultation and take control of your tax situation.

Visit our Liens, Levies & Garnishments page to learn more or call us directly.