Glossary
The vocabulary of Collection Due Process, defined once and used consistently across this site.
- Form 12153
- The IRS form used to request a Collection Due Process hearing or an Equivalent Hearing after a levy notice or Notice of Federal Tax Lien filing.
- Collection Due Process (CDP) hearing
- A hearing before the IRS Independent Office of Appeals, requested within 30 days, that suspends levy action, tolls the collection statute, and preserves Tax Court review.
- Equivalent Hearing
- A hearing available when the 30-day CDP deadline is missed — within 1 year — that gives an Appeals conference but no automatic levy suspension, no CSED tolling, and no Tax Court review.
- IRS Independent Office of Appeals
- The independent IRS function that conducts CDP and Equivalent Hearings and issues the Notice of Determination or Decision Letter.
- Notice of Determination
- The document Appeals issues after a CDP hearing. It starts a 30-day window to petition the U.S. Tax Court.
- Decision Letter
- The document Appeals issues after an Equivalent Hearing. Unlike a Notice of Determination, it generally carries no Tax Court petition right.
- Collection Statute Expiration Date (CSED)
- The date, generally 10 years from assessment, after which the IRS can no longer collect a tax debt. A timely CDP request suspends it for the hearing period plus 90 days.
- Notice of Federal Tax Lien (NFTL)
- The public filing that secures the government's claim against your property. Its filing triggers separate lien CDP rights via Letter 3172.
- Notice of Intent to Levy
- The final notice (CP90, CP297, LT11, or Letter 1058) that gives 30 days to request a CDP hearing before the IRS can levy.
- Trust Fund Recovery Penalty (TFRP)
- A penalty assessed against responsible persons for unpaid trust fund employment taxes. Letter 1153 is the 'prior opportunity' that can affect whether liability can be contested at CDP.
- Collection alternatives
- Options to resolve a balance short of levy — installment agreements, partial-pay installment agreements, offers in compromise, and currently not collectible status.
- Balancing test
- Under §6330(c)(3)(C), Appeals must weigh efficient collection against the taxpayer's concern that the action be no more intrusive than necessary.