What Are the Main IRS Collection Appeal Procedures?

Collection Due Process, an equivalent hearing, and the
Collection Appeals Program are different procedures.
They do not provide identical deadlines, collection
protections, or opportunities for court review.

The IRS explains these procedures in

Publication 1660, Collection Appeal Rights
.

When Is a Collection Due Process Hearing Available?

CDP rights can arise from notices concerning the filing
of a Notice of Federal Tax Lien or a qualifying levy action.
Examples include certain LT11 notices, Letters 1058,
and lien hearing notices.

A levy notice generally provides a 30-day period to request
a CDP hearing. Lien hearing deadlines use a different
calculation connected to the lien filing. Review the
actual notice and its stated filing deadline.

A telephone conversation with the IRS does not, by itself,
extend the deadline for submitting the hearing request.

Our

IRS notices guide

can help you identify the type of correspondence you received.

What Can You Raise in a CDP Hearing?

Depending on the circumstances, a CDP hearing may address
whether collection procedures were followed, whether the
proposed action is appropriate, and whether a collection
alternative should be considered.

Alternatives may include an installment agreement,
an offer in compromise, or a request based on financial
hardship. Supporting returns and financial information
may be required.

Challenging the underlying tax liability is subject to
separate eligibility rules, including whether you received
a notice of deficiency or previously had an opportunity
to dispute the liability. A CDP hearing is not an automatic
opportunity to reopen every earlier tax determination.

Does a CDP Request Stop IRS Collection?

A timely CDP request generally restricts levy action for
the taxes and periods covered by the hearing while the
applicable process is pending. Statutory exceptions apply.
It does not automatically release an existing levy,
remove a lien, or protect unrelated tax periods.

A timely request also generally suspends the period the
IRS has to collect the covered tax. The procedural
protection should therefore be considered together with
its effect on the collection deadline.

What If You Missed the CDP Deadline?

An equivalent hearing may still be available if requested
within the applicable one-year period. The starting date
depends on whether the case involves a levy notice or
a lien filing.

Do not assume you have one additional year after the
missed CDP deadline. An equivalent hearing must also
be requested; an untimely CDP request is not automatically
converted into one in every case.

An equivalent hearing does not create the same statutory
prohibition on levy or suspend the collection statute
merely because that hearing was requested. Any
administrative collection hold must be evaluated separately.

The resulting decision generally does not provide the
same Tax Court review right as a CDP determination.
A disagreement about whether the original request was
timely requires separate analysis.

How Does the Collection Appeals Program Work?

CAP may be available for specified collection actions
before or after they occur, including certain lien,
levy, seizure, and installment agreement decisions.
It focuses on the appropriateness of the collection
action rather than redetermining the underlying tax.

A discussion with a Collection manager is generally
required before certain CAP appeals. Different rules
apply to installment agreement appeals. Some
collection-action procedures involve deadlines measured
in business days.

Form 9423 is commonly used for a written CAP request.
It is not interchangeable with Form 12153, which is
used to request a CDP or equivalent hearing.

Collection protection under CAP depends on the action,
applicable law, and IRS procedures. The CAP decision
itself does not carry a right to judicial review.

What to Gather Before an Appeal Review

• The complete notice, including every page and its envelope.
• The tax types and periods involved.
• Earlier notices about the same liability.
• Records of previous responses or hearing requests.
• Relevant returns, payments, and account information.
• Financial records supporting any proposed payment
  arrangement or hardship request.

If a representative will handle the matter, the authorization
must cover the appropriate tax matters and periods.
Our

Form 2848 authorization guide

explains what that authorization permits.

Questions About IRS Collection Appeals

Does Every Intent-to-Levy Notice Offer the Same Appeal Rights?

No. A CP504 notice should not be treated as interchangeable
with an LT11 or Letter 1058. Review the exact notice,
its hearing language, and any earlier notices before
deciding which procedure applies.

Does Calling the IRS Preserve My Hearing Deadline?

No. A phone call alone does not replace a required timely
hearing request. Follow the applicable submission
instructions and retain evidence of submission.

What Happens After a CDP Determination?

A CDP determination generally carries a separate 30-day
period to petition the United States Tax Court.
Court proceedings have separate filing and representation
requirements. Review the determination promptly.

Does an Appeal Eliminate the Tax Debt?

No. An appeal provides a procedure for reviewing issues
within its scope. Any account adjustment, collection
alternative, or other relief depends on the facts
and applicable requirements.

Get Help Reviewing Your Collection Notice

Polaris Tax & Accounting provides Enrolled Agent
representation in IRS administrative collection and
appeal matters. We review the notice, account history,
available procedures, and supporting information
before recommending a response.

For the broader resolution process, review our

IRS tax resolution guide
.

Request a collection-notice review

or call
704-947-3178.
Include the notice number and response deadline
in your initial inquiry.