In theory, there has been a right to "Collection Due Process" when the IRS collects taxes since 2000. In reality, out of 15,000,000 collections and about 3,000 contested cases, only 16 taxpayers have prevailed. The analysis also makes a deeper point:
Some commentators contend there can be no proper “rule of law” without adversarial process. This study proves the opposite claim: adversarial process, used in the wrong place and the wrong time, becomes a rule of deception rather than a rule of law.