The IRS will file a lien against a business when they continue to be ignored. A business has 30 days to protest the action. If you disagree with the placement of the lien, you can protest the action with the Manager of the Revenue Officer placing the lien. This must be done within the requisite time frames. If you still disagree, an appeal to the IRS Appeal’s Office and then to the U.S. Tax Court and further to U.S. District Court may be filed. If you choose to go further with protesting the lien, it is strongly recommended that you retain counsel familiar with the IRS Code and rules and procedures in appearing before the requisite courts. Time is of the essence. You must adhere to the guidelines or you will lose your rights to protest.