Collection Due Process (CDP)

You are entitled to a CDP hearing before Appeals if the IRS sends you a notice concerning a proposed levy, a notice of levy, or a Notice of Federal Tax Lien, if such notice states you have the right to request a CDP hearing. 

CDP Procedure

  • You have 30 days to request a CDP hearing
  • Complete Form 12153, Request for a Collection Due Process or Equivalent Hearing
    • It is important to identify all the reasons for any disagreement you have.
  • The completed Form 12153 should be sent to the same address that is shown on your CDP Notice
  • If your request is timely made within 30 days, you will be entitled to an Appeals hearing and to seek judicial review of that hearing with the Tax Court 
  • If your request is timely, IRS levy action is generally suspended against you for the tax periods you appealed. 
  • If your request is not timely, you are still entitled to request an Equivalent Hearing with Appeals within the 1-year period described in the Form 12153. However, if you still disagree with the Appeals decision in the Equivalent Hearing you have no right to judicial review by the Tax Court

For more information please refer to: