The Three Divisions of IRS Enforcement

When taxpayers hear “IRS,” they don’t think of the federal agency’s IT infrastructure, information services, and behind-the-scenes operations support. Taxpayers are primarily concerned with the IRS’ ability to collect taxes, audit their tax returns, and, in worst-case scenarios, investigate tax crimes. 

The forward-facing component of the IRS is usually referred to as the enforcement division. There are numerous branches and departments within the IRS, but this blog will take a closer look at the three divisions of IRS enforcement: collection, examination, and criminal investigation. 


The collection division is focused on collecting tax liabilities that are owed to the IRS by taxpayers. The collection division is not concerned with taxpayer appeals or disputes over the amount owed. The collection division employs a semi-tiered system for collecting unpaid taxes. Usually, the first several notices a taxpayer receives are automated notifications. These notices continue to get more threatening and hostile.  The IRS will warn taxpayers that it may file a federal tax lien and may levy on their bank account or wages. Eventually, a revenue officer will be tasked with collection. 

The IRS has a number of tools to compel payment from taxpayers. You may get a federal tax lien filed against you, which is a claim to your property and proceeds from any sale of your property. Levies are a seizure of property or wages, or a garnishment of future funds by the IRS. If you are dealing with the collection subdivision, our firm can help you negotiate an installment agreement or an offer in compromise. 


If you’re unfortunate enough to be selected for an IRS audit, you’ll be dealing with the examination division of the IRS.  Many audits are not performed in-person. In fact, audits are often conducted through notices in the mail. 

The first letter in your audit will let you know the documents the IRS wants to examine and the general nature of the reason for the audit. While audits rarely result in criminal charges, it’s best to hire an attorney to guide you through your audit. 

Criminal Investigation (CI)

Only the most serious and consequential cases get handled by IRS criminal investigators. These agents commonly investigate allegations of tax crimes, including tax fraud, tax evasion, false statements on a tax return, and criminal failure to file. It’s worth noting that arrests by the CI division are rare. The IRS tends to investigate and make criminal charges in a case that they are confident the government will prevail, and cases that will make an example to the public. As soon as you realize you may be a subject or target of an IRS criminal investigation, it’s time to call your attorney. 


Most people spend their time trying not to think about the IRS and its myriad departments, divisions, and subdivisions. When you get involved in a tax dispute, it helps to know the delineation of responsibilities and subject matters across the IRS. Most interactions with any part of the IRS are best conducted with an attorney’s advice and counsel.

Weisberg Kainen Mark, PL understands the complexities of tax cases and has decades of experience defending clients in this niche area. We know the stresses you’re feeling, and we can get you on a better path. Call our team at (305) 374-5544 to see how we can help.

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Weisberg Kainen Mark, PL

As experienced trial lawyers with a passion for justice, our firm provides clients with compelling advocacy, attorney availability, and creative solutions to your tax or criminal law matters.

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