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What happens if the CDP request is filed on time?
PostedNovember 17, 2025
UpdatedNovember 17, 2025
ByKlemens Raab
All IRS collection activity for the listed tax periods is legally suspended while Appeals reviews the case. The IRS cannot levy assets, garnish wages, or seize property during this time.
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Collection Appeals
- What triggered the creation of IRS Collection Due Process (CDP) rights?
- What is the benefit of invoking CDP rights?
- What percentage of taxpayers currently request a CDP hearing?
- When can a taxpayer request a CDP hearing?
- How is a CDP hearing requested?
- What happens if the CDP request is filed on time?
- What if the taxpayer owes for older years not covered by the CDP request?
- What should practitioners include in Form 12153?
- Who handles the CDP hearing?
- How is a CDP hearing conducted?
- What must taxpayers provide to Appeals before a CDP hearing?
- What is a Notice of Determination?
- Can the taxpayer appeal the Notice of Determination?
- What is the legal standard in Tax Court for CDP cases?
- What is an Equivalent Hearing?
- When must an Equivalent Hearing be requested?
- How do you request an Equivalent Hearing?
- What happens if Box 2 is not checked when requesting an Equivalent Hearing?
- What is the Collection Appeals Program (CAP)?
- What actions can be appealed under CAP?
- What steps must be taken before filing a CAP appeal?
- What form is used for a CAP appeal?
- How soon will a Settlement Officer respond after filing a CAP appeal?
- Can taxpayers challenge the amount they owe during a CDP hearing?
- What should practitioners do if underlying liability is disputed?
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