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Overview of IRS Collection Appeals

Posted by Juda Gabaie | Nov 30, 2023 | 0 Comments

It can be stressful and overwhelming if you've received notices from the IRS stating that you have an unpaid tax balance. As long as the agency believes you have an unpaid tax debt, it will continue to try to collect by filing a lien or a levy. With a lien or a levy, the IRS will attempt to claim your assets or property to satisfy the debt. But you have the right to appeal a collection decision you don't agree with. In this post, we'll discuss an overview of the appeals process for IRS collections.

1. Collection Due Process Hearing

When you receive a notice of a federal tax lien filing, the intent to file a lien, or the notice of a levy from the IRS, it will list a deadline to request a Collection Due Process (CDP) hearing. You can request a CDP hearing if the notice you receive from the IRS says you can, and you must request the hearing within the deadline. If you miss the deadline to request a CDP hearing, you may be able to request an “equivalent hearing.” If you disagree with a CDP hearing decision, you can contest it in U.S. Tax Court.

2. Collection Appeals Program

The Collection Appeals Program (CAP) is often faster and more flexible than a CDP hearing, applying to a wider range of IRS actions. However, you can't contest a CAP decision in court or challenge the amount of your tax liability. But you can use the CAP process earlier in dispute. You don't have to wait for a final notice of intent to file a lien or levy. CAP is binding on both you and the IRS. However, once you utilize the CAP process, you can't later request a CDP hearing.

A Skilled Tax Attorney Can Help You

If you're facing challenges trying to resolve a tax issue with the IRS, we can help. It's important to have a professional skilled in negotiating with the IRS and guiding individuals and businesses through the appeal process. We represent clients across the U.S. in complex and simple tax matters. Call Gabaie & Associates, LLC at 410-358-1500 or contact us online for a free consultation.

About the Author

Juda Gabaie

Juda Gabaie Esq. has dedicated his career in defending clients nationwide to resolve tax disputes before the Internal Revenue Service and the state taxing agencies. Juda has represented clients before the US Tax Court, Maryland Tax Court, and Comptroller of MD hearing compliance. As an adjunct prof...


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