IRS collection activity declined sharply early in the period and then increased in several visible measures. The six-fiscal-year series, FY 2020 through FY 2025, shows more delinquent-return investigations, more lien and third-party levy activity than the FY 2022 trough, and a large payment-plan program.
What the six-fiscal-year data show
- New taxpayer delinquency investigations increased from 59,964 in FY 2023 to 2,501,667 in FY 2025.
- Notices of federal tax lien rose from 157,323 in FY 2022 to 214,099 in FY 2025.
- New installment agreements reached 3.16 million in FY 2025.
Delinquent-return investigations and collection notices increased
New delinquency investigations rose more than forty-fold from the FY 2023 trough to FY 2025. Notices of federal tax lien and third-party levy notices also rose from their FY 2022 lows, though both remained below FY 2020 levels. These are activity measures and notices, not a count of unique taxpayers or a measure of amounts actually seized.
| Measure | FY 2020 | FY 2022 | FY 2025 |
|---|---|---|---|
| Liens filed | 291,081 | 157,323 | 214,099 |
| Third-party levies | 396,269 | 273,286 | 339,137 |
| Seizures | 77 | 89 | 50 |
| New delinquency investigations | 2,257,180 | 469,458 | 2,501,667 |
Payment plans remain the most common published resolution measure
New installment agreements grew from 2.36 million in FY 2021 to 3.16 million in FY 2025, while installment-agreement collections rose to $17.9 billion. Offer-in-compromise acceptances fell from 15,154 to 5,464 across those years. Offers received and accepted in the same fiscal year are not the same cohort, so the figures should not be treated as an acceptance rate or as proof that one program replaced the other.
| Measure | FY 2021 | FY 2025 |
|---|---|---|
| Offers received | 49,285 | 38,797 |
| Offers accepted | 15,154 | 5,464 |
| New installment agreements | 2,361,646 | 3,160,047 |
| IA collections | $13.7B | $17.9B |
Account count declined in FY 2025, assessed balance did not
The number of delinquent accounts fell from 14.9 million to 13.1 million in FY 2025 as closed accounts exceeded new accounts. The assessed balance in delinquent accounts nevertheless rose from about $208.4 billion to $211.5 billion. Those are different measures, and the series does not establish why either changed.
A lien or levy notice has strict procedural consequences. Readers should focus on the notice, tax period, and response deadline rather than a national trend line. For a high-stakes collection matter, Tax Controversy & Litigation provides a more appropriate next step.
Methodology and sources
Collection figures are from IRS Data Book Table 4-1. A single taxpayer can generate multiple notices and accounts, so the tables do not measure the number of taxpayers affected. The IRS collection tables and IRS Data Book archive provide the source editions.
Related reading
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A 1932 constitutional amendment presumes every tax paid after 30 years. Whether that protection reaches California income-tax collection remains an open question.
IRS Enforcement Trends: What FY 2021 to 2025 Data Show
A five-year IRS Data Book reference on audit closures, high-income examinations, CP2000 notices, and nonfiler enforcement.
IRS Appeals and Tax Court Trends: FY 2021 to 2025
A five-year IRS Data Book reference on Appeals workload, Collection Due Process inventory, and the Tax Court docket.
This article provides general information based on published IRS and federal oversight data. It does not constitute legal advice and does not create an attorney-client relationship.