Collection Due Process (CDP) Hearing
An appeal heard before the IRS levies, available only on notices that carry the right. Requested on Form 12153 within the window your notice states — miss it and the fallback hearing cannot be taken to Tax Court.
Full Definition
A Collection Due Process hearing is an appeal to the IRS Independent Office of Appeals, heard before the IRS levies. The right exists under Internal Revenue Code section 6330 and it is carried by particular notices, not by every collection letter.
The IRS states that LT11 and Letter 1058 — which are the same notice — tell you it intends to seize your property or rights to property, and that you may request a collection due process hearing. Its CP297 page says the same. CP504 does not carry the right, which is the distinction most often got wrong.
There is a fallback if the deadline passes, and its cost is the part that matters. The Taxpayer Advocate Service states that where a CDP request is not timely you may request an Equivalent Hearing within one year of the CDP notice date, on the same Form 12153 — but that if you disagree with the Appeals decision from an Equivalent Hearing, you cannot take it to Tax Court. So the deadline does not remove your ability to be heard; it removes your ability to be reviewed by a court afterwards.
What to do next
Work from the date printed on your notice, not the day you received it, and check whether the notice actually says you have a right to a hearing. If it does and the window is still open, file Form 12153 to the address on that notice.
What this page does not say
- The one-year Equivalent Hearing window is sourced here to the Taxpayer Advocate Service, which is a secondary source. Treat the date on your own notice and the IRS instructions printed with it as controlling.
Sources
- Understanding your LT11 notice or letter 1058 — Internal Revenue Service, retrieved 2026-08-20
- 26 U.S.C. §6330 — Notice and opportunity for hearing before levy — United States Code, retrieved 2026-08-18
- Equivalent Hearing (Within 1 Year) — Taxpayer Advocate Service, retrieved 2026-08-20
Last reviewed 2026-08-20 by Tax Resolution Clarity editorial.
Sourced to primary IRS materials and editorially reviewed. Not reviewed by a tax professional. Not tax advice.
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Where to go next
The IRS publishes the rules this page describes. Your own notice governs your dates.