What Is a Collection Due Process Hearing, and How Do I Request One?
A Collection Due Process (CDP) hearing gives you the right to challenge an IRS federal tax lien or proposed levy before an independent Appeals officer. You request it by filing Form 12153 within 30 days of receiving a Notice of Federal Tax Lien filing (Letter 3172) or a final notice of intent to levy (LT11 or CP504). Filing a timely CDP request suspends IRS levy action and preserves your right to petition the U.S. Tax Court if you disagree with the outcome.
- 30-day deadline from the date on your lien or levy notice to file Form 12153
- Levy action paused while your CDP hearing is pending
- Tax Court access preserved if you file on time
- Equivalent hearing available within one year if you miss the 30-day window (but no levy suspension or Tax Court rights)
What you can raise at a CDP hearing:
| Issue | Example |
| Collection alternative | Installment agreement, Offer in Compromise, or currently not collectible status |
| Spousal defense | Innocent spouse or equitable relief under IRC 6015 |
| Underlying liability | Only if you had no prior opportunity to dispute the tax |
| Appropriateness of action | Whether the lien or levy is warranted given your circumstances |
How to file:
- Complete Form 12153 with your name, address, SSN, the tax periods at issue, and the reasons for your request.
- Mail to the address on your lien or levy notice.
- Keep proof of mailing (certified mail recommended) since the 30-day deadline is firm.
Expats should factor in international mail times. If you are overseas and receive a lien or levy notice, consider faxing Form 12153 to the number on your notice to meet the deadline while the mailed copy is in transit.
Last updated on April 29, 2026
