Form 12153 (Request for a Collection Due Process or Equivalent Hearing)

Full Definition

Form 12153, Request for a Collection Due Process or Equivalent Hearing, is how a CDP hearing is requested. The IRS directs recipients of CP297 — a notice of intent to levy that states "You have the right to a Collection Due Process hearing" — to request that hearing on Form 12153, and says you can appeal the intent to levy and other disagreements you have at the hearing.

Publication 1660 says to complete Form 12153, or another written request carrying the same information, and send it to the address shown on your lien or levy notice. The Taxpayer Advocate Service states that filing a timely request protects your right to go to Tax Court — which is the practical difference between this route and the Collection Appeals Program, where the IRS states an Appeals decision is not itself open to judicial review, while adding that other review routes may remain for the underlying issue.

Whether this form is the right one depends on the notice you actually received. Not every collection notice carries CDP rights; CP504 does not.

Sources

• Understanding your CP297 notice — Internal Revenue Service, retrieved 2026-08-20
• Publication 1660, Collection Appeal Rights — Internal Revenue Service, retrieved 2026-08-18
• Collection Due Process (CDP) — Taxpayer Advocate Service, retrieved 2026-08-18

Last reviewed 2026-08-20 by Tax Resolution Clarity editorial.