Research

The IRS Collections and Enforcement Report 2026: Liens, Levies, and Criminal Investigation

By The Ledgerism Editorial Team · The Ledgerism Brief Editorial Team produces original, methodology-disclosed accounting and tax research—data trackers, databases, and reference guides built to be the most-cited source in the field. Every figure is verified against primary sources including FASB, the IRS, the PCAOB, NASBA, the AICPA, and state boards of accountancy.

A data profile of the IRS Collection function and IRS Criminal Investigation for Fiscal Years 2020 through 2025, built entirely from primary federal sources. This report covers the collection and criminal-enforcement side of tax administration. It does not cover examinations (audits), which are reported separately.

Fiscal-year note: the IRS fiscal year runs October 1 through September 30. FY2025 ended September 30, 2025, and is the most recent complete year in the IRS Data Book.

Executive summary

• The IRS filed 214,099 Notices of Federal Tax Lien in FY2025, up from a modern low of 157,323 in FY2022, a 36.1% increase over three years (Source: IRS Data Book 2025, Table 4-1; IRS Data Book 2023, Table 27).
• The IRS requested 339,137 notices of levy on third parties in FY2025, the highest annual total since FY2020 (Source: IRS Data Book 2025, Table 4-1).
• The IRS conducted only 50 physical seizures of property in FY2025, the lowest count in the FY2020 through FY2025 window (Source: IRS Data Book 2025, Table 4-1).
• The IRS Collection function netted $73.1 billion from returns filed with additional tax due in FY2025, after $44.4 billion in credit transfers, on a gross yield of $117.5 billion (Source: IRS Data Book 2025, Table 4-1).
• Taxpayers submitted 38,797 offers in compromise in FY2025, but the IRS accepted only 5,464, a 14.1% acceptance rate that is the lowest in the six-year window and down from 42.1% in FY2023 (Source: IRS Data Book 2025, Table 4-1; IRS Data Book 2023, Table 27).
• The IRS held 13,112,485 taxpayer delinquent accounts in ending inventory in FY2025, carrying $211.5 billion in assessed tax, penalties, and interest (Source: IRS Data Book 2025, Table 4-1).
• IRS Criminal Investigation initiated 2,792 investigations and secured 1,611 convictions in FY2025, reporting an 89% conviction rate (Source: IRS Data Book 2025, Table 3-10; IRS-CI FY2025 Annual Report).
• IRS-CI identified almost $4.5 billion in tax fraud and over $6 billion in other financial-crime fraud in FY2025 (Source: IRS-CI FY2025 Annual Report).

Key findings

• The IRS filed 214,099 Notices of Federal Tax Lien in FY2025, versus 196,996 in FY2024 and 179,019 in FY2023 (Source: IRS Data Book 2025, Table 4-1; IRS Data Book 2023, Table 27).
• Levy notices to third parties reached 339,137 in FY2025, up 8.1% from 313,792 in FY2024 (Source: IRS Data Book 2025, Table 4-1).
• Physical seizures fell to 50 in FY2025 from 71 in FY2024, and remain a fraction of the roughly 3.6 million new installment agreements handled annually (Source: IRS Data Book 2025, Table 4-1).
• The gross collection yield from unpaid assessments was $117.5 billion in FY2025, down slightly from $120.2 billion in FY2024 (Source: IRS Data Book 2025, Table 4-1).
• Net amount collected on returns with additional tax due was $73.1 billion in FY2025, up 90.2% from $38.5 billion in FY2020 (Source: IRS Data Book 2025, Table 4-1; IRS Data Book 2021, Table 25).
• The IRS assessed $29.6 billion on returns not filed timely in FY2025 and collected almost $3.5 billion with delinquent returns (Source: IRS Data Book 2025, Table 4-1).
• Offers in compromise received rose to 38,797 in FY2025 while acceptances fell to 5,464, a divergence that pushed the acceptance rate to 14.1% (Source: IRS Data Book 2025, Table 4-1).
• The dollar value of accepted offers fell to $98.1 million in FY2025 from $214.5 million in FY2023 (Source: IRS Data Book 2025, Table 4-1; IRS Data Book 2023, Table 27).
• New installment agreements established totaled 3,160,047 in FY2025, and the IRS collected $17.9 billion from accounts in installment-agreement status (Source: IRS Data Book 2025, Table 4-1).
• Ending taxpayer-delinquent-account inventory was 13,112,485 accounts in FY2025, down from 14,901,508 in FY2024 (Source: IRS Data Book 2025, Table 4-1).
• Taxpayer delinquency investigations (nonfiler cases) surged, with 2,501,667 new investigations opened in FY2025 versus 639,143 in FY2024 (Source: IRS Data Book 2025, Table 4-1).
• IRS-CI initiated 2,792 criminal investigations and completed 2,850 in FY2025 (Source: IRS Data Book 2025, Table 3-10).
• IRS-CI obtained 1,726 indictments and informations and 1,611 convictions in FY2025 (Source: IRS Data Book 2025, Table 3-10).
• Of those sentenced by IRS-CI in FY2025, 75.9% were incarcerated (Source: IRS Data Book 2025, Table 3-10).
• IRS-CI referred 2,043 cases for prosecution in FY2025 and reported an 89% conviction rate (Source: IRS-CI FY2025 Annual Report; IRS Data Book 2025, Table 3-10).

Collection function: definitions and scope

The IRS Collection function collects taxes that have been reported or assessed but not paid, and secures returns that were not filed. This is distinct from the Examination (audit) function, which determines whether a return is correct. A case typically enters Collection after assessment: the IRS issues balance-due notices, then may escalate to a Notice of Federal Tax Lien (a public legal claim against property), a levy (seizure of funds such as bank accounts or wages held by third parties), or, rarely, a physical seizure of property conducted by field revenue officers (Source: IRS Data Book 2025, Table 4-1 footnotes).

Key terms used in this report, per IRS definitions:
– Notice of Federal Tax Lien (NFTL): a lien request entered into the IRS Automated Lien System. It secures the government’s interest and is public record.
– Notice of levy: a levy requested on third parties by the Automated Collection System and Field Collection programs.
– Seizure: a physical seizure of property conducted by the Field Collection program.
– Offer in compromise (OIC): a taxpayer proposal to settle a liability for less than the full amount owed.
– Installment agreement (IA): an arrangement to pay tax liabilities over time.
– Taxpayer delinquent account (TDA): an assessed, unpaid balance in active collection status.
– Taxpayer delinquency investigation (TDI): a nonfiler case opened when a taxpayer does not respond to a notice of a delinquent return.

Liens, levies, and seizures

Enforcement actions collapsed during the pandemic and the 2020 People First Initiative, then rebuilt through FY2025 without returning to pre-2010 levels. Notices of Federal Tax Lien bottomed at 157,323 in FY2022, the lowest in the modern series, and have risen for three consecutive years to 214,099 in FY2025. Levy notices followed a similar path. Physical seizures remain vanishingly rare in absolute terms, never exceeding 100 in any year of this window and falling to 50 in FY2025.

Source: IRS Data Book 2025, Table 4-1 (FY2024, FY2025); IRS Data Book 2023, Table 27 (FY2022, FY2023); IRS Data Book 2021, Table 25 (FY2020, FY2021).

What the numbers mean: the FY2020 elevated lien and levy counts partly reflect actions in the first half of that fiscal year, before the People First Initiative suspended new NFTLs and many levies from April 1, 2020, through September 30, 2020. The subsequent trough (FY2022) and three-year rebuild is consistent with restored staffing and resumed automated collection. Seizures are a lagging, discretionary, high-effort action and should not be read as a proxy for overall enforcement intensity.

Collections revenue and delinquent accounts

The Collection function’s net yield from returns filed with additional tax due grew from $38.5 billion in FY2020 to $73.1 billion in FY2025. This “amount collected” is collection-enforcement yield on assessed-but-unpaid balances, not total IRS receipts (the IRS collects trillions annually in gross receipts). The delinquent-account balance carried in ending inventory rose to $211.5 billion in FY2025.

Source: IRS Data Book 2025, Table 4-1; IRS Data Book 2023, Table 27; IRS Data Book 2021, Table 25. Money amounts in thousands of current dollars.

Context and limitation: the TDA ending balance ($211.5 billion in FY2025) reflects assessed tax, penalties, and interest on accounts in active collection status. It excludes accrued (unassessed) penalties and interest and is not the same as the government’s total outstanding tax debt or the tax gap. It is the closest single “balance-due” measure the Data Book publishes at the collection-activity level.

Offers in compromise

Offers in compromise let taxpayers settle for less than the full liability. FY2025 shows a sharp squeeze: more taxpayers applied, but far fewer were accepted, and the total dollars accepted fell to the lowest in the window.

Source: IRS Data Book 2025, Table 4-1; IRS Data Book 2023, Table 27; IRS Data Book 2021, Table 25. Acceptance rate is a derived figure (accepted ÷ received); see Original synthesis.

What the numbers mean: acceptance rate is calculated on offers received in the same year, so it is an approximation because offers can be received in one fiscal year and decided in another. Even allowing for that lag, the two-year fall from 42.1% (FY2023) to 14.1% (FY2025) is large and coincides with rising volume of submissions. The report flags this as a directional signal, not a case-level closure rate.

Installment agreements

Installment agreements are the highest-volume collection resolution by far, dwarfing liens, levies, and seizures combined. New agreements established have run above 3.1 million per year in FY2024 and FY2025.

Source: IRS Data Book 2025, Table 4-1; IRS Data Book 2023, Table 27; IRS Data Book 2021, Table 25.

IRS Criminal Investigation (CI)

IRS-CI is the criminal-enforcement arm of the IRS and the only federal agency with jurisdiction over federal tax crimes. In FY2025 it operated with roughly 2,000 special agents (Source: IRS-CI FY2025 Annual Report). Investigations span three programs: legal-source tax crimes, illegal-source financial crimes, and narcotics-related financial crimes. Because investigations cross fiscal years, dispositions in a given year relate to cases initiated in that or prior years.

Source: IRS Data Book 2025, Table 3-10.

FY2025 financial impact (from the IRS-CI FY2025 Annual Report): IRS-CI identified almost $4.5 billion in tax fraud and over $6 billion in fraud linked to other financial crimes. It referred 2,043 cases for prosecution and saw 1,611 convictions, reporting a conviction rate of 89%. Special agents spent approximately 23.7% of their time investigating non-tax violations and initiated 1,412 such cases (Source: IRS-CI FY2025 Annual Report).

Conviction-rate flag: the IRS-CI FY2025 Annual Report states an 89% conviction rate. Using Data Book Table 3-10, convictions (1,611) divided by indictments and informations (1,726) yields 93.3%. The two figures use different denominators; the IRS-CI headline rate is the officially reported enforcement metric, and both are disclosed here.

Original synthesis

Insight 1: The Enforcement Rebuild Index (liens + levies, indexed to the FY2022 trough)

Logic: index the sum of NFTLs filed and third-party levy notices to the FY2022 trough (=100) to measure how far civil enforcement has recovered. Inputs: NFTL and levy counts, IRS Data Book Tables 4-1/27/25.

Finding: combined civil enforcement actions are 28.5% above the FY2022 trough as of FY2025, but still 19.5% below the FY2020 level (index 159.6). Limitation: FY2020 is distorted upward by pre-pandemic first-half activity; the index measures action counts, not dollars recovered.

Insight 2: The Offer-in-Compromise Squeeze (acceptance rate, derived)

Logic: acceptance rate = offers accepted ÷ offers received within the same fiscal year. Inputs: IRS Data Book Tables 4-1/27/25.

Finding: the OIC acceptance rate fell from a window-high 42.1% in FY2023 to 14.1% in FY2025, a 28-percentage-point drop over two years, even as submissions rose from 30,163 to 38,797. Average dollars per accepted offer also fell, from about $16,874 in FY2023 ($214.48M ÷ 12,711) to about $17,961 in FY2025 ($98.146M ÷ 5,464); the total accepted dollars fell 54.2% because far fewer offers cleared. Limitation: same-year acceptance rate is an approximation because offers can be received and decided in different fiscal years; the sharpness of the two-year move exceeds what lag alone would explain, but the exact case-level closure rate is not published in this table.

Insight 3: The Levy-to-Seizure Ratio (enforcement escalation profile)

Logic: divide third-party levy notices by physical seizures to show how heavily the IRS relies on automated third-party collection versus discretionary field seizure. Inputs: IRS Data Book Tables 4-1/27/25.

Finding: in FY2025 the IRS issued roughly 6,783 third-party levy notices for every physical seizure, the most levy-heavy profile in the window and up from about 4,420 in FY2024. Enforcement is overwhelmingly automated and third-party (bank and wage levies), with physical seizure now an exceptional last resort. Limitation: seizure counts are small integers and volatile year to year, so the ratio is sensitive to single-digit changes in the denominator.

Corroborating oversight data (TIGTA)

• For Fiscal Years 2022 through 2024, the IRS had approximately $3.2 billion in unidentified payments and successfully applied $2.3 billion, about 70%, to taxpayer accounts (Source: TIGTA Report 2026-400-024, May 21, 2026).
• As of December 2025, the IRS reported receiving more than 302.6 million payments totaling over $5.4 trillion in the reference calendar-year period (Source: TIGTA Report 2026-400-024, May 21, 2026).
• The Inflation Reduction Act originally provided the IRS nearly $80 billion over 10 years; Congress subsequently reduced IRA funding to $37.6 billion, and as of March 2025 the IRS had spent $13.8 billion (Source: TIGTA, Major Management Challenges Facing the IRS in FY 2026, October 2025).

These figures are context for collection accuracy and funding, not substitutes for the Data Book collection metrics above.

Charts to create

1. “IRS Notices of Federal Tax Lien filed, FY2020 to FY2025.” Data: NFTL counts by year. Source: IRS Data Book Tables 4-1/27/25. Insight: the post-2022 rebuild. Citation-worthy because it quantifies renewed lien activity in a single line.
2. “IRS third-party levies vs. physical seizures, FY2020 to FY2025 (dual axis).” Data: levy notices and seizures by year. Source: same. Insight: enforcement is automated; seizures are near-zero. Citation-worthy for the escalation-profile story.
3. “Offer-in-compromise acceptance rate, FY2020 to FY2025.” Data: offers received, accepted, and derived rate. Source: same. Insight: the acceptance squeeze to 14.1%. Citation-worthy as a taxpayer-relief indicator.
4. “IRS Collection net amount collected vs. delinquent-account balance, FY2020 to FY2025.” Data: net collected and TDA ending balance. Source: same. Insight: rising unpaid balances alongside rising collections. Citation-worthy for the growing-arrears narrative.
5. “IRS-CI outcomes funnel, FY2025.” Data: initiated, referred, indicted, convicted, incarcerated. Source: IRS Data Book Table 3-10. Insight: attrition from investigation to incarceration. Citation-worthy as a criminal-enforcement snapshot.

Methodology

• Source selection: only Tier-1 primary federal sources were used for statistics: the IRS Data Book (Publication 55B, 2025, 2023, and 2021 editions), the IRS-CI FY2025 Annual Report (Publication 3583), and two TIGTA audit reports. No secondary aggregator figures were relied on for any statistic.
• Fiscal-year labeling: every figure is tagged to the IRS fiscal year (October 1 to September 30). FY2025 is the latest complete Data Book period as of the update date.
• Table sourcing: the delinquent-collection-activities table is numbered differently across editions (Table 4-1 in the 2025 Data Book, Table 27 in the 2023 Data Book, Table 25 in the 2021 Data Book). All three were pulled to build a continuous FY2020 through FY2025 series. FY2024 and FY2025 come from the 2025 edition; FY2022 and FY2023 from the 2023 edition; FY2020 and FY2021 from the 2021 edition.
• Derived figures: OIC acceptance rate, the Enforcement Rebuild Index, and the Levy-to-Seizure Ratio are calculated by the author from the primary counts above; formulas and inputs are shown in Original synthesis.
• Conflict handling: where the IRS-CI conviction rate (89%, report) differs from a Data Book-derived ratio (93.3%), both are disclosed with their denominators rather than reconciled to one number.
• Exclusions: no projections or estimates are presented as current. No national “total tax debt” or “tax gap” dollar figure is presented as a collection metric, because the Data Book does not publish it as a collection-activity line; the TDA ending balance is used instead and labeled as such.
• Last updated: 2026-06-29.

Source quality ranking

• Tier 1 (primary government): IRS Data Book 2025 (Publication 55B), Tables 4-1 and 3-10; IRS Data Book 2023 (Table 27); IRS Data Book 2021 (Table 25); IRS-CI FY2025 Annual Report (Publication 3583); TIGTA Report 2026-400-024 (May 21, 2026); TIGTA, Major Management Challenges Facing the IRS in FY 2026 (October 2025).
• Tier 2: none used for statistics.
• Tier 3: none used for statistics.
• Excluded: secondary summaries and law-firm blog posts surfaced during research were used only to locate primary tables and were not cited for any figure. Any statistic that could not be traced to a primary IRS or TIGTA document was omitted.

Citation format

• Source: Internal Revenue Service, Data Book, 2025 (Publication 55B), Table 4-1, Delinquent Collection Activities, Fiscal Years 2024 and 2025.
• Source: Internal Revenue Service, Data Book, 2025 (Publication 55B), Table 3-10, Criminal Investigation Program, by Status or Disposition, Fiscal Year 2025.
• Source: Internal Revenue Service, Data Book, 2023 (Publication 55B), Table 27, Delinquent Collection Activities, Fiscal Years 2022 and 2023.
• Source: Internal Revenue Service, Data Book, 2021 (Publication 55B), Table 25, Delinquent Collection Activities, Fiscal Years 2020 and 2021.
• Source: Internal Revenue Service, Criminal Investigation Annual Report, Fiscal Year 2025 (Publication 3583).
• Source: Treasury Inspector General for Tax Administration, Report 2026-400-024, May 21, 2026.
• Source: Treasury Inspector General for Tax Administration, Major Management Challenges Facing the IRS in FY 2026, October 2025.

Journalist-friendly additions

Most quotable statistics

• The IRS conducted just 50 physical property seizures in all of FY2025, the fewest in six years (IRS Data Book 2025, Table 4-1).
• The IRS accepted only 14.1% of the offers in compromise it received in FY2025, down from 42.1% in FY2023 (IRS Data Book, Tables 4-1 and 27).
• The IRS filed 214,099 Notices of Federal Tax Lien in FY2025, up 36.1% from the FY2022 low (IRS Data Book, Tables 4-1 and 27).
• IRS Criminal Investigation reported an 89% conviction rate on 1,611 convictions in FY2025 (IRS-CI FY2025 Annual Report).
• The IRS issued about 6,783 third-party levy notices for every physical seizure in FY2025 (derived from IRS Data Book 2025, Table 4-1).

Data limitations

• “Net amount collected” is collection-enforcement yield on assessed unpaid balances, not total IRS revenue.
• Seizure and OIC counts are small and can swing sharply year to year; treat single-year changes cautiously.
• The OIC acceptance rate is a same-year approximation because offers can be received and decided in different fiscal years.
• The IRS-CI conviction rate (89%) and the Data Book-derived convictions-per-indictment ratio (93.3%) use different denominators.
• The Data Book does not publish a single national “total tax debt” figure at the collection-activity level; the TDA ending balance is the closest published measure.

Downloadable dataset (recommended fields)

fiscal_year, nftls_filed, levy_notices_third_party, seizures, oic_received, oic_accepted, oic_acceptance_rate_pct, oic_amount_accepted_thousands, net_amount_collected_thousands, gross_yield_thousands, credit_transfers_thousands, tda_ending_count, tda_ending_balance_thousands, ia_new_established, ia_ending_inventory, ia_amount_collected_thousands, ci_investigations_initiated, ci_referrals_for_prosecution, ci_indictments, ci_convictions, ci_sentenced, ci_incarcerated, ci_incarceration_rate_pct, source_publication, source_table.

Press summary (about 150 words)

The IRS Collection function stepped up civil enforcement in Fiscal Year 2025 while making it harder to settle tax debt. The agency filed 214,099 Notices of Federal Tax Lien and issued 339,137 third-party levy notices, both multi-year highs, according to the IRS Data Book 2025. Physical seizures, however, fell to just 50, the fewest in six years, confirming that modern collection is overwhelmingly automated. Offers in compromise tell a squeeze story: taxpayers submitted 38,797 offers but the IRS accepted only 5,464, a 14.1% acceptance rate, down from 42.1% in Fiscal Year 2023. The Collection function netted $73.1 billion on assessed unpaid taxes, while delinquent-account balances rose to $211.5 billion. On the criminal side, IRS Criminal Investigation initiated 2,792 cases, won 1,611 convictions, and reported an 89% conviction rate, identifying almost $4.5 billion in tax fraud. All figures come from primary IRS and TIGTA sources.

Suggested headlines

• “IRS Seizures Hit Six-Year Low as Liens and Levies Climb in FY2025”
• “Offer-in-Compromise Acceptance Rate Falls to 14% as More Taxpayers Apply”
• “IRS Filed 214,000 Tax Liens in FY2025, Up 36% From Its 2022 Low”
• “6,783 Levies Per Seizure: How Automated IRS Collection Has Become”
• “IRS Criminal Investigation Reports 89% Conviction Rate on 1,611 Convictions in FY2025”

FAQs

1. How many tax liens did the IRS file in FY2025? 214,099 Notices of Federal Tax Lien (IRS Data Book 2025, Table 4-1).
2. How many levies did the IRS issue in FY2025? 339,137 notices of levy on third parties (IRS Data Book 2025, Table 4-1).
3. How many seizures did the IRS conduct in FY2025? 50 physical seizures by the Field Collection program (IRS Data Book 2025, Table 4-1).
4. How many offers in compromise did the IRS accept in FY2025? 5,464 of 38,797 received, worth $98.1 million (IRS Data Book 2025, Table 4-1).
5. What was the OIC acceptance rate in FY2025? About 14.1%, derived from accepted divided by received (IRS Data Book 2025, Table 4-1).
6. How much did the IRS collect through the Collection function in FY2025? $73.1 billion net on returns with additional tax due, after $44.4 billion in credit transfers (IRS Data Book 2025, Table 4-1).
7. How many installment agreements did the IRS establish in FY2025? 3,160,047 new agreements; the IRS collected $17.9 billion from accounts in IA status (IRS Data Book 2025, Table 4-1).
8. What was the IRS delinquent-account balance in FY2025? $211.5 billion across 13,112,485 accounts in ending inventory (IRS Data Book 2025, Table 4-1).
9. How many criminal investigations did IRS-CI initiate in FY2025, and how many convictions? 2,792 initiated and 1,611 convictions (IRS Data Book 2025, Table 3-10).
10. What was the IRS-CI conviction rate in FY2025? 89%, as reported in the IRS-CI FY2025 Annual Report; the Data Book convictions-per-indictment ratio is 93.3%.

Sources

1. Internal Revenue Service, Data Book, 2025 (Publication 55B), Table 4-1 (Delinquent Collection Activities, FY2024 and FY2025) and Table 3-10 (Criminal Investigation Program, FY2025). https://www.irs.gov/pub/irs-pdf/p55b.pdf ; Table 4-1 data: https://www.irs.gov/statistics/soi-tax-stats-delinquent-collection-activities-irs-data-book-table-4-1 ; Table 3-10 data: https://www.irs.gov/statistics/soi-tax-stats-criminal-investigation-program-by-status-or-disposition-irs-data-book-table-3-10
2. Internal Revenue Service, Data Book, 2023 (Publication 55B), Table 27 (Delinquent Collection Activities, FY2022 and FY2023). https://www.irs.gov/pub/irs-prior/p55b–2024.pdf
3. Internal Revenue Service, Data Book, 2021 (Publication 55B), Table 25 (Delinquent Collection Activities, FY2020 and FY2021). https://www.irs.gov/pub/irs-prior/p55b–2022.pdf
4. Internal Revenue Service, Criminal Investigation Annual Report, Fiscal Year 2025 (Publication 3583). https://www.irs.gov/pub/irs-pdf/p3583.pdf ; index: https://www.irs.gov/compliance/criminal-investigation/irs-criminal-investigation-annual-reports
5. Treasury Inspector General for Tax Administration, Report 2026-400-024, IRS Programs That Resolve Billions of Dollars in Unidentified Taxpayer Payments Need to Be Improved and Modernized, May 21, 2026. https://www.tigta.gov/sites/default/files/reports/2026-05/2026400024fr.pdf
6. Treasury Inspector General for Tax Administration, Major Management Challenges Facing the IRS in FY 2026, October 2025. https://www.tigta.gov/sites/default/files/reports/2025-10/FY%202026%20MMC%20(Final).pdf
7. Internal Revenue Service, Collections, Activities, Penalties, and Appeals (statistics landing page). https://www.irs.gov/statistics/collections-activities-penalties-and-appeals

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