IRS Collection Activity Is Increasing in 2026

The IRS has resumed aggressive collection efforts in 2026 following years of reduced enforcement during the pandemic. Taxpayers with outstanding balances are now seeing a sharp increase in collection activity, including notices of federal tax liens, bank levies, wage garnishments, and direct outreach from IRS Revenue Officers.

This shift reflects the IRS’s renewed focus on enforcement and backlog reduction. With expanded funding and staffing initiatives underway, the agency is prioritizing collection of delinquent accounts that may have gone unaddressed in prior years. As a result, taxpayers who have delayed action are now facing more immediate and assertive collection measures.

Ignoring IRS correspondence can quickly escalate the situation. What may begin as a routine notice can lead to enforced collection actions if not addressed promptly. In many cases, delays limit available [tax resolution options] and increase the overall balance due to ongoing penalties and interest. Once enforcement actions begin, they can significantly disrupt both personal finances and business operations.

In particular, Revenue Officer cases are becoming more common. Unlike automated notices, Revenue Officers handle cases directly and often move quickly to secure financial information, request documentation, and pursue enforced collection if compliance is not achieved. Early engagement is critical when a case reaches this stage.

Fortunately, several resolution options may be available depending on your financial circumstances, including:

• Installment Agreements - Structured payment plans that allow taxpayers to resolve liabilities over time while avoiding more aggressive enforcement.


• Offers in Compromise - A negotiated settlement with the IRS that may allow taxpayers to resolve their liability for less than the full amount owed, subject to strict financial qualification.

• Currently Not Collectible status - Temporary suspension of collection activity for taxpayers experiencing financial hardship.

• Penalty Abatement - Reduction or removal of certain penalties where reasonable cause or first-time relief criteria apply.

Each of these options requires careful evaluation, accurate financial disclosure, and strategic communication with the IRS. Submitting incomplete or inconsistent financial information can delay resolution or result in denial of relief. A well-prepared and proactive approach is essential to achieving a favorable outcome.

Taxpayers should also be aware that timing is critical. Certain rights and protections—such as Collection Due Process (CDP) hearings—are only available within specific deadlines. Missing these deadlines can significantly limit available remedies and negotiation leverage.

At Wilson Tax Law Group, we represent individuals and businesses in federal and state tax controversy matters. Our team works directly with taxing authorities to develop tailored resolution strategies designed to protect our clients and efficiently resolve outstanding liabilities.

If you have received IRS notices or have unresolved tax debt, it is important to act now before enforcement escalates.

If you have any questions regarding your individual or businesses’ state and/or federal tax return(s)/tax liabilities or received a notice from the IRS, FTB, EDD, CDTFA or any other regulatory agency, please call or email Wilson Tax Law Group, APLC, to setup a consultation with our firm.

Wilson Tax Law Group, APLC is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. Firm founder, Joseph P. Wilson, is a former Federal tax prosecutor and trial attorney for the IRS and California Franchise Tax Board. Wilson Tax Law Group, APLC, is comprised of former IRS litigators & Special Agents, and Assistant US Attorneys from the US Attorney’s Office, Central District of California, Tax Division, which at the time handled both civil tax lawsuits and criminal tax prosecutions on behalf of the United States of America.

For further information, or to arrange a consultation please contact: Wilson Tax Law Group, APLC

Tel: (949) 397-2292 (Newport Beach Office)

Tel: (714) 463-4430 (Yorba Linda Office)

Disclaimer: This blog post is for informational purposes only and does not constitute legal, tax or financial advice. Please consult with a qualified attorney, accountant or financial advisor for specific guidance related to your circumstances.

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Joseph P. Wilson Named to the 2026 Super Lawyers List

Wilson Tax Law Group is pleased to announce that founding attorney Joseph P. Wilson has once again been selected to the 2026 Super Lawyers® list for Southern California.

Super Lawyers is a nationally recognized rating service that honors outstanding attorneys who have attained a high degree of peer recognition and professional achievement. The selection process is highly competitive and includes independent research, peer nominations, and peer evaluations across multiple indicators of professional accomplishment.

Mr. Wilson’s continued recognition reflects his long-standing dedication to representing individuals and businesses in complex tax matters, including IRS examinations, tax controversy, and litigation. Throughout his career, he has built a reputation for providing thoughtful, strategic representation while guiding clients through challenging and often high-stakes tax issues.

At Wilson Tax Law Group, our team remains committed to delivering the same level of diligence, professionalism, and personalized service that clients have come to expect. Mr. Wilson’s recognition by Super Lawyers highlights the firm’s ongoing commitment to excellence in tax law and client advocacy.

Please join us in congratulating Joseph P. Wilson on this well-deserved recognition.

To find out more about how Wilson Tax Law Group, APLC, could help with your tax litigation and defense needs, we invite you to set up a consultation with our firm.

Wilson Tax Law Group, APLC is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. Firm founder, Joseph P. Wilson, is a former Federal tax prosecutor and trial attorney for the IRS and California Franchise Tax Board. Wilson Tax Law Group, APLC, is comprised of former IRS litigators & Special Agents, and Assistant US Attorneys from the US Attorney’s Office, Central District of California, Tax Division, which at the time handled both civil tax lawsuits and criminal tax prosecutions on behalf of the United States of America.

For further information, or to arrange a consultation please contact: Wilson Tax Law Group, APLC

Tel: (949) 397-2292 (Newport Beach Office)

Tel: (714) 463-4430 (Yorba Linda Office)

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Disclaimer: This blog post is for informational purposes only and does not constitute legal advice. Please consult with a qualified attorney for specific guidance related to your circumstances.

Got an IRS Notice? Don’t Leave It to Luck

Take control early—IRS issues don’t resolve themselves.

St. Patrick’s Day is often associated with luck—four-leaf clovers, good fortune, and the idea that things will somehow work out. However, when it comes to dealing with the IRS, relying on luck is rarely what leads to a favorable outcome. More often, successful resolutions come from timely action, clear understanding, and the right guidance.

When IRS Issues First Arise

Most individuals and business owners do not seek assistance because everything is going smoothly. Instead, they reach out after receiving an IRS notice, learning they are being audited, or realizing that a tax balance has grown beyond what they anticipated.

The initial instinct is often to set the issue aside with the intention of addressing it later. While that reaction is understandable, it can allow the situation to become more difficult to manage over time.

Why Delays Can Make Matters Worse

IRS matters continue to progress whether or not they are addressed. Notices have deadlines, and failing to respond can lead to additional penalties, increased interest, and, in some cases, enforcement actions.

What may begin as a relatively straightforward issue can become significantly more complex simply due to inaction. Addressing the matter early often preserves more options and allows for a more controlled and strategic resolution.

How We Help Clients Navigate IRS Challenges

Our work focuses on guiding clients through these situations with a practical and informed approach. This includes responding to IRS notices, representing clients during audits, managing document requests, and working toward resolution of outstanding tax liabilities.

Equally important, we communicate directly with the IRS on our clients’ behalf and provide a clear understanding of where things stand and what steps come next. While every case is unique, there is almost always a path forward when the issue is addressed directly.

Taking the First Step

For many people, the most difficult part is simply getting started. Opening the notice, asking questions, or seeking guidance can feel overwhelming. However, once the situation is addressed, it often becomes far more manageable.

Clarity replaces uncertainty, and a structured plan replaces the stress of the unknown.

A Different Perspective on “Luck”

St. Patrick’s Day serves as a reminder that what often feels like luck is really the result of timing and action. When it comes to IRS matters, taking that first step sooner rather than later can make a meaningful difference in both the process and the outcome.

A Simple Reminder

If you have received an IRS notice, are facing an audit, or have unresolved tax issues, addressing the matter now can help you regain control and move forward with confidence.

We’re here when you’re ready.

If you have any questions regarding your individual or businesses’ state and/or federal tax return(s)/tax liabilities or received a notice from the IRS, FTB, EDD, CDTFA or any other regulatory agency, please call or email Wilson Tax Law Group, APLC, to setup a consultation with our firm.

Wilson Tax Law Group, APLC is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense.  Firm founder, Joseph P. Wilson, is a former Federal tax prosecutor and trial attorney for the IRS and California Franchise Tax Board.  Wilson Tax Law Group, APLC, is comprised of former IRS litigators & Special Agents, and Assistant US Attorneys from the US Attorney’s Office, Central District of California, Tax Division, which at the time handled both civil tax lawsuits and criminal tax prosecutions on behalf of the United States of America.

For further information, or to arrange a consultation please contact: Wilson Tax Law Group, APLC

Tel: (949) 397-2292 (Newport Beach Office) 

Tel: (714) 463-4430 (Yorba Linda Office)

 

Associate Tax Attorney, Brian S. Trinh, joins Wilson Tax Law Group, APLC

We recently issued a press release announcing Brian S. Trinh's addition to the firm. Since joining, he has already been actively supporting our clients, strengthening our practice, and making meaningful contributions to our team. We're pleased to officially share the news.

 

CA’s Proposed Billionaire Tax: Key Planning Risks

Once again, California is at the center of a national tax debate and we are tuning in to gain a better perspective on what this means for high-net worth individuals. A proposed ballot initiative, commonly referred to as the “2026 Billionaire Tax Act,” has sparked significant concern among high-net worth individuals, family offices, and closely held business owners. While the measure is not yet law, its potential impact is serious enough that proactive planning is no longer optional.

What is being proposed?

The initiative would impose a one-time tax on individuals and certain trusts with net-worth exceeding $1 billon, reportedly at a rate up to 5%. Unlike traditional income or capital gains taxes, this proposal targets wealth itself, including assets that may be difficult to value, such as business interests, real estate, or private investments.

Although marketed as a limited, one-time assessment, history shows that “temporary” taxes often become precedent for future expansion, in scope and frequency.

Why this matters before passage?

From a legal and planning standpoint, the mere existence of the proposal creates risk. High-net worth taxpayers should be aware of several immediate concerns. Several immediate concerns may include residency and domicile scrutiny over perceived tax avoidance, valuation disputes over privately held assets, trust structures and asset ownership may come under closer review, and retroactivity concerns could trigger constitutional challenges and litigation. We believe it is important to get ahead of these concerns as waiting for clarity could be an expensive strategy.

Suggested tips

While it might be too early to take drastic action based solely on a proposal, it is an ideal time to meet with your trusted tax attorney, not just your preparer, to review your asset structures and trust planning, evaluate residency risk and documentation, identify audit vulnerabilities tied to asset reporting, valuations, and prior filings, stress-test valuations of significant holdings, and coordinate tax planning with legal, estate, and wealth advisors. Unlike CPA’s, a trusted tax attorney can advise on legal risk, audit defense, constitutional issues, and privilege-protected planning. When dealing with proposed taxes that raise questions about valuation disputes, retroactivity, and enforcement authority, legal strategy matters as much as tax math.

Concluding Remarks

Proposed tax laws often change, stall, or fail. However, now is not the time to ignore them which could be a costly mistake. California’s proposed billionaire tax highlights a broader trend toward aggressive state-level taxation of wealth. High-net worth individuals should stay informed, proactive, and well-advised. If you are concerned with how this proposal could affect you and/or your business, please reach out today and setup a consultation to discuss different strategies on how to properly plan for protection under the guidance of one of the firm’s trusted tax attorneys.

If you have any questions regarding your individual or businesses’ state and/or federal tax return(s)/tax liabilities or received a notice from the IRS, FTB, EDD, CDTFA or any other regulatory agency, please call or email Wilson Tax Law Group, APLC, to setup a consultation with our firm.

Wilson Tax Law Group, APLC is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense.  Firm founder, Joseph P. Wilson, is a former Federal tax prosecutor and trial attorney for the IRS and California Franchise Tax Board.  Wilson Tax Law Group, APLC, is comprised of former IRS litigators & Special Agents, and Assistant US Attorneys from the US Attorney’s Office, Central District of California, Tax Division, which at the time handled both civil tax lawsuits and criminal tax prosecutions on behalf of the United States of America.

For further information, or to arrange a consultation please contact: Wilson Tax Law Group, APLC

Tel: (949) 397-2292 (Newport Beach Office) 

Tel: (714) 463-4430 (Yorba Linda Office)

Disclaimer: This blog post is for informational purposes only and does not constitute legal, tax or financial advice. Please consult with a qualified attorney, accountant or financial advisor for specific guidance related to your circumstances.

Risks Behind “My CPA Approved It”

One of the most common and most dangerous statements we have heard from California taxpayers who are being audited is: “My CPA said it was fine.”

While CPAs play a vital role in tax preparation and compliance, that statement does not provide legal protection when the Internal Revenue Service or the Franchise Tax Board challenge your filed tax returns.

Understanding the difference between tax preparation and tax defense can mean the difference between a manageable audit and a financially devasting outcome.

CPA Advise Does Not Equal Legal Protection

Auditors do not evaluate whether your CPA believed a position was reasonable. They evaluate whether the position complies with tax law. If it does not comply, liability rests with the taxpayer; not the tax preparer.

Many taxpayers are also surprised to learn that communications with a CPA are generally not protected by attorney-client privilege. In an audit or dispute, emails, notes, and explanations shared with a preparer may be requested and used as evidence against you.

“Good Faith Reliance” Does Not Stop Penalties

Another common misconception is that replying on a CPA automatically eliminates penalties. In reality, even when a CPA prepared a return, taxpayers may still face back taxes, interest, accuracy-related penalties, or negligence penalties. In California, these amounts can escalate quickly due to compounding interest and aggressive enforcement practices.

Audits Are Not About Preparation, They’re About Defense

Once an audit begins, the process becomes adversarial. Auditors are trained to identify unsupported deductions, residency and sourcing errors, misclassified income, or aggressive or inconsistent positions. At this stage, continuing without legal representation can expose taxpayers to unnecessary risk. How information is presented and how much is disclosed, matters.

Why a Tax Attorney Changes the Outcome

A trusted tax attorney’s role is not to re-prepare the tax return, but to defend it. This includes assessing legal exposure, controlling communication with taxing authorities, determining whether positions can be defended, negotiated, or mitigated, and preserving attorney-client privilege.

Bottom Line for California Taxpayers

CPAs are essential for compliance and planning. However, when an audit, notice, or dispute arises, CPA approval does not equate to legal protection.

The real question is not whether something was “fine” at the time; it is whether it can withstand scrutiny now. Early involvement of an experienced and trusted tax attorney can reduce penalties, limit exposure, and prevents small issues from becoming major financial liabilities.

Because in tax audits, what matters most is not who prepared the return, it is who knows how to defend it.

If you have any questions regarding your individual or businesses’ state and/or federal tax return(s)/tax liabilities or received a notice from the IRS, FTB, EDD, CDTFA or any other regulatory agency, please call or email Wilson Tax Law Group, APLC, to setup a consultation with our firm.

Wilson Tax Law Group, APLC is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense.  Firm founder, Joseph P. Wilson, is a former Federal tax prosecutor and trial attorney for the IRS and California Franchise Tax Board.  Wilson Tax Law Group, APLC, is comprised of former IRS litigators & Special Agents, and Assistant US Attorneys from the US Attorney’s Office, Central District of California, Tax Division, which at the time handled both civil tax lawsuits and criminal tax prosecutions on behalf of the United States of America.

For further information, or to arrange a consultation please contact: Wilson Tax Law Group, APLC

Tel: (949) 397-2292 (Newport Beach Office) 

Tel: (714) 463-4430 (Yorba Linda Office)

Disclaimer: This blog post is for informational purposes only and does not constitute legal, tax or financial advice. Please consult with a qualified attorney, accountant or financial advisor for specific guidance related to your circumstances.