Can the IRS file an NFTL even if the taxpayer owes less than $50,000?

Yes. Although the IRS often waits until the tax debt exceeds $50,000 before automatically filing an NFTL, IRS employees have the discretion to file the notice for smaller balances if they believe It is necessary to protect the government\’s interest. The decision can be influenced by the taxpayer\’s payment history, financial situation, and compliance behavior.