Overview

The IRS cannot pursue every tax problem at once, so it ranks cases by likely return on enforcement, legal urgency, and risk to public interests. This prioritization shapes whether a taxpayer receives gentle notices, an installment offer is accepted, or the case escalates to liens, levies, or referral to criminal investigation. (See IRS Publication 594 for a high-level summary of the collections process.)

Key factors the IRS uses

  • Amount owed: Larger balances often move to the front of the queue because they restore more revenue quickly.
  • Type of tax: Trust fund and payroll taxes are treated aggressively because they involve other people’s money and employer responsibilities.
  • Compliance history: Repeated nonfiling or unpaid assessments over multiple years raises priority.
  • Ability to pay: Accounts where the IRS believes assets are available (bank accounts, wages, property) are more likely to be enforced.
  • Statutory deadlines and local priorities: Cases nearing the statute of limitations for collection or related to national enforcement campaigns may be fast-tracked.
  • Criminal indicators: Evidence suggesting fraud or criminal activity will change both prioritization and the type of enforcement (civil vs. criminal referral).

How the IRS selects actions

The IRS combines automated filters, data analytics, and human review. Automated systems flag accounts based on thresholds (dollar amount, age of debt, tax type, repeated filing failures). Revenue Officers and Automated Collection System (ACS) specialists then review flagged cases and choose actions — notices, installment negotiations, liens, or levies — consistent with legal rules and local office priorities (IRS, “Understanding the IRS Collection Process”).

Real-world examples

  • Payroll tax debt: In my practice I’ve seen payroll-tax cases prioritized because the IRS can assess trust fund recovery penalties and pursue levies quickly to protect employee withholdings.
  • Unfiled returns with large tax exposure: Multiple years of unfiled tax returns with substantial estimated tax due commonly receive early attention because the IRS can estimate tax and issue assessments.

Who is most likely to be targeted

Taxpayers with large outstanding balances, repeated noncompliance, payroll/trust fund tax issues, available bank assets or wage sources, or involvement in schemes that trigger enforcement campaigns are most likely to face rapid escalation.

Practical steps taxpayers should take now

  1. Respond immediately to any IRS notice. Nonresponse increases the likelihood of liens and levies.
  2. If you can pay, offer a prompt payment or set up a plan. For many taxpayers, an installment agreement is the practical path — see our guide on setting up an installment agreement for details and comparisons to other relief options (setting up an installment agreement).
  3. If you truly cannot pay, evaluate relief options. Filing an Offer in Compromise can be appropriate in limited cases; our walkthrough on filing an offer explains documentation and eligibility (filing an Offer in Compromise).
  4. If a levy is threatened or issued, act fast. There are emergency steps and challenges you can pursue — see our guide on how to challenge a levy for immediate options (how to challenge an IRS levy).

Common mistakes to avoid

  • Ignoring IRS notices. Silence is the single biggest error — it removes options and can speed enforcement.
  • Assuming small debts won’t be pursued. Size matters, but repeated noncompliance or certain tax types can trigger action even on moderate balances.
  • Not documenting changed financial circumstances. If your ability to pay changes, provide current records promptly; the IRS uses your bank and wage data to reassess ability to pay.

Short FAQs

  • Can I slow the process? Yes — timely response, negotiating an installment agreement, or submitting a hardship request can pause or redirect enforcement.
  • Does priority mean criminal referral? Not automatically. Civil collection is the typical path; criminal referrals occur only when indicators of criminal tax behavior appear.

Sources and practical context

  • IRS, Publication 594: The IRS Collection Process (IRS.gov)
  • IRS, Understanding the IRS Collection Process (IRS.gov)

In my experience as a tax practitioner, early engagement with the IRS and well-documented financial statements materially improves outcomes. If you face potential enforcement, consult a qualified tax professional to assess options for installment agreements, Offers in Compromise, or levy challenges.

Professional disclaimer

This article is educational and does not replace individualized tax advice. Laws and IRS procedures evolve; consult a tax professional for guidance specific to your situation.