Collection Due Process Program (Completed)

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Collection Due Process (CDP) hearings are one of the most important taxpayer protections created by the IRS Restructuring and Reform Act of 1998 (RRA 98). CDP hearings provide taxpayers with an independent review by the IRS Office of Appeals of the IRS’s decision to file a Notice of Federal Tax Lien (NFTL) or the IRS’ proposal to take levy action. In this class, we will explore what correspondence from the IRS triggers CDP rights, how to request a CDP hearing and best practices for advocating for your client during the hearing process.

Topics Covered

• Purpose and history of the CDP rights
• Correspondence that provides for CDP rights
• IRC Section 6320, Notice of Federal Tax Lien Filing and Right to a Hearing
• IRC Section 6330, Notice of Intent to levy and Right to Hearing
• Exceptions to Pre-Levy Notice
• Requesting a CDP hearing and the effect of the hearing
• Filing out the Form 12153, Request for a Collection Due Process or Equivalent Hearing
• How CDP hearings are conducted

Learning Objectives

• Recognize the IRS correspondence that provides a taxpayer with a right to request a collection due process (CDP) hearing
• Understand how to fill out the Form 12153, Request for a Collection Due Process or Equivalent Hearing
• Understand the difference between a CDP hearing and an equivalent hearing
• Describe hearing resolution options
• Understand that taxpayers can seek Tax Court review of a CDP determination

Level
Basic

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None