What is Form 12153?
Form 12153 is the two-page IRS form a taxpayer uses to request a hearing before the IRS Independent Office of Appeals after a levy or lien notice.
Definition
Form 12153 is the IRS form a taxpayer files to request a Collection Due Process (CDP) hearing or an Equivalent Hearing with the IRS Independent Office of Appeals after receiving a Notice of Intent to Levy or a Notice of Federal Tax Lien filing. Filed within 30 days, it suspends IRS levy action and preserves the right to petition the U.S. Tax Court.
What is Form 12153 used for?
It requests a hearing with the IRS Independent Office of Appeals to review a proposed or filed collection action — a levy or a Notice of Federal Tax Lien — before it goes further.
The form itself is short. Its power is procedural: filed on time, it forces an independent review, suspends levy action while the hearing is pending, and keeps the door to the U.S. Tax Court open.
Who sends the notice that triggers it?
The IRS sends it. Form 12153 arrives as your response to a specific notice, not on its own.
Levy notices include CP90, CP297, LT11, and Letter 1058. The lien notice is Letter 3172, the Notice of Federal Tax Lien filing. The notice you received determines your deadline and which hearing rights you have.
Is Form 12153 free?
Yes. Form 12153 costs nothing to file, and a taxpayer can file it without hiring anyone. What a representation firm charges for is the work at the hearing — reading transcripts, choosing a strategy, and arguing the case — not the form.
What does the form ask for?
The form asks for:
- Your name, address, and taxpayer identification number (TIN)
- The notice you are responding to
- The tax periods involved
- Your reason for disagreement — this must be specific. Writing only “I disagree” is not enough.
- The relief you are requesting — for example an installment agreement, offer in compromise, currently not collectible status, innocent spouse relief, or lien withdrawal, subordination, or discharge.
What are the two hearing types?
Filed within 30 days, Form 12153 requests a Collection Due Process (CDP) hearing. Filed after the 30 days, it can request an Equivalent Hearing — an Appeals conference that lacks the CDP protections. The difference between them is significant.
What happens after you file?
Appeals assigns the case to a settlement or Appeals officer. The conference is usually held by phone. After considering verification, any liability challenge, and collection alternatives, and applying the balancing test, Appeals issues a Notice of Determination (CDP) or a Decision Letter (Equivalent). A Notice of Determination starts a 30-day window to petition the U.S. Tax Court.