Appendix D: Source Notes
Explore the book's legal and IRS references, including sources for updated collection-appeal guidance, court-filing rules and editorial changes.
The legal framework in this book is drawn from the Internal Revenue Code, principally sections 6015 (innocent spouse relief), 6020 (substitute returns), 6159 (installment agreements), 6320 and 6330 (Collection Due Process), 6321 through 6325 (liens), 6331 through 6334 (levy and exempt property), 6343 (release of levy), 6404 (interest abatement), 6502 (collection statute), 6651 (failure-to-file and failure-to-pay penalties), 6656 (failure-to-deposit penalty), 6662 (accuracy penalty), 6672 (Trust Fund Recovery Penalty), 7122 (Offers in Compromise), and 7345 (passport certification), together with the Treasury Regulations under those sections.
IRS procedure is drawn from the Internal Revenue Manual, particularly Part 5 (Collecting Process): sections 5.8 (Offers in Compromise), 5.11 (Levy), 5.12 (Liens), 5.14 (Installment Agreements), 5.15 (Financial Analysis), 5.16 (Currently Not Collectible), and 5.19 (Liability Collection), and Part 20.1 (Penalty Handbook). The Manual is public at IRS.gov.
Statistics on offers received and accepted and on gross collections are from the IRS Data Book for fiscal year 2025. The ratio of offers accepted to offers received in a fiscal year is not a true acceptance rate, because the two figures do not describe the same cohort of applications.
IRS workforce figures and the warnings about 2026 taxpayer service are from the National Taxpayer Advocate's 2025 Annual Report to Congress, released January 28, 2026, and the accompanying IRS news release IR-2026-15 (https://www.taxpayeradvocate.irs.gov/wp-content/uploads/2026/01/IR-2026-15.pdf).
The Offer in Compromise application fee, payment terms, and low-income certification are from Form 656 and the Form 656-B booklet, revised April 2026 (https://www.irs.gov/pub/irs-pdf/f656.pdf), and IRS Tax Topic 204 (https://www.irs.gov/taxtopics/tc204).
Taxpayer rights are from the Taxpayer Bill of Rights as adopted by the IRS in 2014 and codified in section 7803(a)(3) in 2015, and from IRS Publication 1, Your Rights as a Taxpayer. Collection procedures for individuals are summarized by the IRS in Publication 594, The IRS Collection Process. Wage levy exemption amounts are in Publication 1494, updated annually. Collection Financial Standards are published on IRS.gov and updated annually.
The judicial decisions referenced include the Supreme Court decision United States v. Boyle, 469 U.S. 241 (1985), on reliance on an agent to file, and Vinatieri v. Commissioner, 133 T.C. 392 (2009), on hardship levy release where returns are unfiled.
Dollar thresholds, fees, standards, and form revisions change. Every figure in this book that is indexed or administratively set should be checked against the current IRS.gov page before it is relied on. The principles do not change nearly as often as the numbers.
For the published collection-appeal and court-filing revisions, see IRS Publication 1660, Collection Appeal Rights, current Form 12153 and instructions, Tax Court guidance for starting a case, and Boechler v. Commissioner. Boechler concerns the CDP court-petition deadline; it must not be presented as a blanket extension of all tax-litigation deadlines. Dated editorial changes are recorded in Source Notes.