Question 1

What is a Collection Due Process (CDP) hearing?

Accepted Answer

A CDP hearing is your right under IRC sections 6320 and 6330 to challenge IRS collection actions (liens and levies) before an independent Appeals officer. You must request the hearing within 30 days of receiving a Notice of Determination.

Question 2

How long do I have to request a CDP hearing?

Accepted Answer

You have 30 days from the date of the CDP notice to request a hearing. If you miss this deadline, you may still request an equivalent hearing, but you will lose your right to petition the Tax Court.

Question 3

Can I challenge the underlying tax liability at a CDP hearing?

Accepted Answer

You can challenge the underlying liability only if you did not receive a statutory notice of deficiency or did not otherwise have a prior opportunity to dispute the liability.

Question 4

What collection alternatives can I raise at a CDP hearing?

Accepted Answer

You can raise collection alternatives including installment agreements, offers in compromise, currently not collectible (CNC) status, and other arrangements. The Appeals officer must consider whether the proposed collection action balances the government's need for efficient collection with your concern that collection be no more intrusive than necessary.

Collection Due Process Hearing Guide

Understand Your Collection Due Process Hearing Rights

Deadlines

Collection Alternatives

Standard of Review

Underlying Liability

IRC § 6330

IRC § 6320