•The IRS files too many liens against people with few or no assets, which does nothing but damage those taxpayers' financial viability. "Simply raising the dollar threshold for lien filings does not provide for the level of thoughtful judgment that should serve as the basis for the use of this powerful collection tool," she said.

• The IRS automatically files liens without enough analysis of their effects on citizens and government coffers. The agency, Olson said, "continues to establish lien filing policies without any evidence that automatic lien filings generate significant revenue as compared to the financial devastation they visit on taxpayers."

Olson praised some aspects of the IRS's announced actions, including those applying to small businesses. But she decried the agency's failure to more proactively contact taxpayers earlier in the collection process to work out alternatives. Taxpayers, who may not even recieve initial IRS mailings, may conclude the agency is ignoring the debt, she said. Only after penalties and interest increase that debt to an unmanageable load does the IRS issue its "calling card" in the form of a lien.

"The IRS's failure to engage taxpayers early, when the debts are small and fresh, is the root cause of many taxpayer cases with collection problems," Olson stated.

Earlier this year, in her annual report to Congress, the National Taxpayer Advocate argued that tax liens might do more harm than good.—Tobie Stanger