You disagree with an IRS decision

Collection Due Process, or CDP, provides an administrative hearing about specified lien or levy actions. • Review IRC § 6320 for lien hearings and IRC § 6330 for levy hearings. • Identify LT11, Letter 1058, CP90 or Letter 3172 and the rights each notice provides. • Check the 30-day request period and the actual date printed on the notice. • Prepare Form 12153 when the hearing request is supported. • If the CDP request is late, review an equivalent hearing within one year and its different protections. You receive a summary of the applicable hearing route and response date.

The issues Appeals may consider depend on the type of dispute and your earlier opportunities to challenge it. • Compare an installment agreement, an offer in compromise or currently not collectible status. • Review spousal defenses and procedural errors. • Check whether the underlying liability can be disputed at the hearing. • For an examination appeal, organize disputed facts, legal arguments and additional records. • Explain litigation risks without predicting a settlement. You receive the agreed written position and its supporting evidence.

An Appeals conference allows you or an authorized representative to present the supported position. • Confirm the applicable collection restrictions rather than assuming an existing levy is released. • A timely CDP request generally suspends levy action, subject to legal exceptions. • Present the facts and any supported collection alternative to the Appeals officer. • Review the Notice of Determination and any 30-day Tax Court petition period. • Explain suspension of the generally 10-year collection period during the CDP process. You receive a conference and decision summary, including any further review dates.

The engagement defines the administrative appeal and records we will prepare; the IRS decides the requested administrative relief. • Review the notice, account information and supporting documents. • Prepare the agreed hearing request or protest. • Present the authorized administrative case and review the response. • Coordinate any court-related support with Tax Court-admitted counsel, who handles court representation. You receive the written scope, submission records and next-step summary.