How long do I have to file Form 12153?
For levy notices, 30 days from the date on the notice. For a lien, 30 days after a 5-business-day filing window. Miss it and an Equivalent Hearing is the most that remains.
Deadline for levy notices
For CP90, CP297, LT11, and Letter 1058, you have 30 days from the date on the notice to file Form 12153 and preserve full CDP rights.
Deadline for the lien notice
For a lien (Letter 3172), the timing has two parts. The IRS must send the notice within 5 business days of filing the Notice of Federal Tax Lien. You then have 30 days after that 5-business-day period to request a lien CDP hearing.
What if I miss the 30 days?
You can still request an Equivalent Hearing. The window is longer, but the rights are weaker.
- Levy: within 1 year of the levy notice date.
- Lien: 1 year plus 5 business days after the Notice of Federal Tax Lien filing.
Rules people miss
- Each spouse on a joint return must file separately. One filing does not preserve the other spouse's rights.
- One CDP hearing per tax period, per action type. Lien and levy are separate — a hearing on one does not use up your right to the other.