Written by Sam Brotman, J.D., LL.M. (Taxation), MBA — Managing Attorney, Brotman Law  ·  Updated May 2026

IRS Collections Activity in San Diego

IRS collections in the San Diego area is handled by the Northern California Collection Area. Most collection cases begin with the IRS Automated Collection System (ACS) — a centralized operation that sends balance due notices and processes payments by phone and mail. When ACS cannot resolve a case, it is assigned to a local Revenue Officer.

Revenue Officers from the 880 Front Street, Suite 2226, San Diego, CA 92101 territory are field collection employees with significant enforcement authority. They can:

• Issue a summons requiring the taxpayer or third parties to produce financial records
• File a Notice of Federal Tax Lien (NFTL), which attaches to all property and rights to property
• Recommend a levy on wages, bank accounts, accounts receivable, or other assets
• Recommend seizure of physical property in extreme cases
• Make referrals to IRS Criminal Investigation when they encounter potential fraud during collection activity

Once a Revenue Officer is assigned, the matter has moved past ACS and formal representation is essential. Interacting with a Revenue Officer without a Form 2848 Power of Attorney on file risks giving information that narrows your resolution options.

Resolution Options for San Diego Taxpayers

There is no single right answer for every IRS collections case — the best option depends on the taxpayer’s financial situation, the size of the liability, the age of the tax years, and other factors. The options available under the Internal Revenue Code include:

• Installment Agreement (IA): A monthly payment arrangement under IRC § 6159. Streamlined agreements are available for balances under $50,000 that can be paid in 72 months. Larger balances require a Collection Information Statement (Form 433-A or 433-B) and financial disclosure. Interest continues to accrue during an installment agreement. See our installment agreements page for more detail.
• Offer in Compromise (OIC): An offer to settle the full tax liability for less than the amount owed, accepted by the IRS when it is in the government’s best interest under IRC § 7122. The IRS evaluates the taxpayer’s Reasonable Collection Potential (RCP) — the sum of net realizable asset equity plus future income. See our OIC page.
• Currently Not Collectible (CNC) status: A temporary suspension of collection activity under IRM 5.16 when the taxpayer has no ability to pay. CNC status is not permanent — the IRS can return the case to active collections if the taxpayer’s financial situation improves.
• CSED analysis: The IRS has 10 years from assessment to collect under IRC § 6502. If the remaining collection window is short, a strategy of compliance without aggressive resolution may be appropriate, depending on the circumstances.
• Penalty Abatement: First-time abatement (FTA) under IRM 20.1.1.3.6.1 is available to taxpayers with a clean compliance history for the three preceding years. Reasonable cause abatement is available when the taxpayer had a legitimate reason for non-compliance.

Local Context: How IRS Collections Actually Works in San Diego

Federal tax matters in San Diego are handled out of the IRS San Diego field office at 880 Front Street, Suite 2226, San Diego, CA 92101. Our office is in Del Mar Heights (12636 High Bluff Drive, Suite 300), about 20 minutes north on the I-5. Most of our IRS field meetings on San Diego cases happen downtown. The downtown federal complex houses the IRS, the U.S. Attorney’s Office for the Southern District of California, and (across the plaza) the Edward J. Schwartz United States Courthouse — where most federal tax matters affecting San Diego residents are litigated when they reach district court.

For practical purposes, that means:

• IRS field interactions — Revenue Officer territory meetings, Office Audit appointments, and IRS-CI subject interviews typically happen downtown rather than at a satellite office.
• U.S. District Court for the Southern District of California — refund suits, criminal tax indictments, and § 7402 collection actions are heard at the Schwartz Courthouse at 221 W. Broadway. Tax matters in this district are heard by the active SDCA bench, with criminal tax cases historically drawing the more experienced trial judges.
• U.S. Bankruptcy Court for the Southern District of California — discharge of older federal tax debts is litigated at 325 W. F Street, three blocks from the IRS office. Bankruptcy and IRS collection often interact more than most clients expect.
• U.S. Tax Court calendars — the Tax Court does not have a permanent San Diego location, but it sends judges to San Diego two to three times a year for trial sessions. San Diego taxpayers typically litigate Tax Court matters here rather than traveling to Los Angeles or San Francisco.
• California FTB / CDTFA / EDD — the state agencies have local offices serving San Diego: FTB at 7575 Metropolitan Drive, CDTFA at 15015 Avenue of Science (Rancho Bernardo), and EDD at 4641 Frazee Road. Most California state tax matters originating in San Diego are handled out of these offices.

San Diego itself runs the demographic gamut: defense contracting and biotech in Sorrento Valley, tourism and hospitality on the coast, small business across every neighborhood, and the largest military payroll on the West Coast. IRS collections cases out of San Diego frequently involve military pay, contractor revenue, real-estate-heavy balance sheets, and the kinds of cross-border arrangements that come with being a port city. We handle the full range here because our practice is built around it.

What Not to Do

When IRS collections is active, certain responses make the situation significantly worse.

• Do not ignore Revenue Officer contact. Ignoring a Revenue Officer does not make the matter go away — it accelerates it. Revenue Officers have authority to issue summonses and recommend levies, and an unresponsive taxpayer is one whose assets are most at risk.
• Do not provide a financial disclosure without counsel. A Form 433-A or 433-B Collection Information Statement is a formal financial disclosure that the IRS uses to determine how much you can pay. Submitting it without understanding how each line affects your resolution options is a significant mistake.
• Do not enter into an installment agreement without evaluating all options. A monthly payment agreement that is larger than necessary ties up cash flow and eliminates leverage. The IRS will generally accept the minimum it is legally required to accept under its own guidelines.
• Do not assume the balance is correct. IRS assessments can be wrong. Before resolving a collection case, it is worth verifying that the underlying liability is correct and that all applicable credits and payments have been applied.

About Sam Brotman

I am the managing attorney at Brotman Law. I hold a J.D. from the University of San Diego School of Law, an LL.M. in Taxation, and an MBA. I am a member of the California State Bar (Bar No. 274966) and admitted before the U.S. Tax Court. I have been named a Super Lawyer every year since 2016. Brotman Law has resolved more than 2,500 tax matters and over $1 billion in combined tax liabilities since 2013. I represent San Diego-area clients — and clients throughout California — from our San Diego office.