IRS Appeals & CDP Hearings
Challenge IRS Decisions Before an Independent Officer
The IRS Office of Appeals provides an independent review of tax disputes before going to court. Appeals officers have broad authority to settle cases based on hazards of litigation. We've successfully resolved thousands of cases at the appeals level.
Types of Appeals We Handle
From collection actions to audit disputes
Real Results: CDP Appeal
"Client received Notice of Intent to Levy for $234K. We filed CDP hearing request within 30 days, presented OIC during hearing. Appeals officer agreed RCP supported offer. Levy prevented, OIC accepted for $18,500."
*Illustrative scenario. Appeals outcomes depend on case facts and hazards of litigation.
Collection Due Process (CDP) Rights
CDP hearing rights protect you when:
Critical: 30-Day Deadline. You must request a CDP hearing within 30 days of the notice date. Missing this deadline limits your appeal rights.
What You Can Raise at Appeals
At CDP Hearing
- Collection alternatives (IA, OIC, CNC)
- Spousal defenses (innocent spouse)
- Challenge to underlying liability (if not previously contested)
- Procedural errors by IRS
At Examination Appeals
- Factual disputes from audit
- Legal interpretation issues
- New documentation not presented at audit
- Hazards of litigation settlement
Which IRS Notices Trigger CDP Rights
CDP rights are triggered by specific IRS notices. Missing the 30-day response deadline forfeits your right to stop collection and petition Tax Court. If you received any of these, time is critical.
Final Notice of Intent to Levy and Notice of Your Right to a Hearing. Triggers CDP rights for levy action.
IRS Letter LT11 — Intent to Levy equivalent. Often used instead of Letter 1058. Same CDP rights apply.
Final Notice Before Levy on Social Security Benefits. Triggers CDP for Social Security levy action.
Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320. Triggers CDP for lien action.
Deadline Warning: You have exactly 30 days from the date on a CDP notice to file Form 12153. Miss this deadline and you lose levy protection, the ability to raise collection alternatives, and your right to petition U.S. Tax Court for independent judicial review.
What Happens After Filing Form 12153
Collection Suspended
Once Form 12153 is received, the IRS must immediately suspend all levy action. No bank levies, wage garnishments, or asset seizures may proceed while the CDP hearing is pending.
Case Transferred to IRS Office of Appeals
The case moves from Collections to the independent IRS Office of Appeals — a separate division whose job is to resolve cases without litigation.
Appeals Conference Scheduled
An Appeals Settlement Officer (ASO) is assigned. You (or your representative) present your position, supporting documentation, and proposed resolution — in person, by phone, or in writing.
Resolution Negotiated
The ASO evaluates whether collection was appropriate and whether a collection alternative (IA, OIC, CNC) resolves the case fairly. Most CDP hearings result in a negotiated resolution.
Notice of Determination Issued
Appeals issues a Notice of Determination with their ruling. If you disagree, you have 30 days to petition the U.S. Tax Court for judicial review.
Why CDP Appeals Are So Powerful
IRS Authority & References
Related Resolution Services
Resolution Hub Connections
Other Resolution Options
Emergency Relief
Appeals & Monitoring
CDP Triggered by These IRS Notices
Disagree with an IRS Decision?
You have the right to appeal. Let us represent you before an independent Appeals officer to resolve your case without going to court.
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