The IRS has 3 years from the due date of a tax return or date actually filed to examine the return and assess additional taxes penalties and interest. The issue can be elevated to the CID / Criminal Investigation Division if fraud is found or criminal activity is found. IRS has 10 years to collect the deficient taxes. Once the assessment has been made and demand for voluntary compliance fails to materialize then it’s the fun part- knock & lock, seize and sell. No court can intervene. Personal residence seizures now require a plenary procedure but the courts have been a rubber stamp because the evidence speaks for itself.