What is a Collection Due Process (CDP) hearing?
A CDP hearing is an independent review by the IRS Office of Appeals of a proposed levy or a filed tax lien, requested with Form 12153 within 30 days.
What is a CDP hearing?
It is a hearing before the IRS Independent Office of Appeals that reviews whether a levy or lien is appropriate and whether a collection alternative should apply — requested on Form 12153 within 30 days of your notice.
What does a timely CDP request do?
- Suspends levy action by law while the hearing is pending.
- Tolls the Collection Statute Expiration Date (CSED) for the hearing period plus 90 days.
- Preserves Tax Court review — the Notice of Determination can be petitioned within 30 days.
How does the hearing work?
Appeals assigns the case to a settlement or Appeals officer independent of the collection function. The conference is usually by phone. You can present collection alternatives, challenge the underlying liability where allowed, raise procedural and hardship defenses, and require Appeals to verify that the IRS met its legal and procedural requirements.
How does a CDP hearing end?
Appeals issues a Notice of Determination. If you disagree, you have 30 days to petition the U.S. Tax Court, and the levy stays suspended during that review. Appeals also retains jurisdiction if collection later fails to honor the determination.