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When can a taxpayer request a CDP hearing?
PostedNovember 17, 2025
UpdatedNovember 17, 2025
ByKlemens Raab
Only after receiving one of these critical notices:
– Notice of Federal Tax Lien Filing, or
– Final Notice of Intent to Levy (such as Letter 11, Letter 1058, or CP-90).
The 30-day clock to request a hearing starts on the date of the notice.
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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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