Form 12153 requests a Collection Due Process hearing or its equivalent after the IRS sends you a specific lien or levy notice under Internal Revenue Code sections 6320 or 6330. Send the completed request to the hearing-request address printed on your notice, rather than its payment address or directly to Appeals, by the applicable deadline. If you want to fax it, confirm the correct route using the contact instructions on the notice or form. A timely CDP request generally bars levy for the covered matters, subject to statutory exceptions, and suspends the collection limitations period while the CDP proceeding is pending. An equivalent hearing does not provide the same legal levy bar or limitations-period suspension.
Distinguish CDP from equivalent hearing deadlines
Your notice states whether you qualify for a CDP hearing and prints the controlling deadline. For levy CDP requests, the postmark must fall within 30 days after the levy notice date. Lien CDP timing is less intuitive: the IRS must give notice within five business days after filing the Notice of Federal Tax Lien. The 30-day request period follows that five-business-day period; use the deadline shown on the notice. An equivalent hearing remains available for one year after a levy CDP notice or one year plus five business days after lien filing if you miss the CDP window, but you forfeit the levy prohibition, collection-statute suspension, and Tax Court review of the Appeals determination that a timely CDP hearing would provide.
Keep a copy of your signed Form 12153 and proof of mailing with a legible postmark or certificate. Verify the actual deadline and applicable timely-filing rules immediately if the notice date or mailing date is unclear.
Complete the form sections strategically
Item 2 on the current form requests an equivalent hearing if the request does not meet the timely CDP requirements; review the instructions before choosing that fallback. Section 7 requests tax type and periods, but the instructions confirm you may omit this detail if you attach the CDP notice itself. Section 8 asks for your reasons—state factual disputes, procedural objections, or liability challenges if you had no prior opportunity to contest the underlying tax, keeping in mind that a statutory deficiency notice already provided one such opportunity for income and certain other taxes. Section 9 lists collection alternatives you propose, such as an installment agreement, offer in compromise, or currently-not-collectible status; financial statements support these alternatives but are not required with the initial request and can be submitted during the hearing itself.
The taxpayer or both spouses sign and date the form. An authorized representative may sign if a valid Form 2848 power of attorney is already on file or attached. Include the reasons for your request and relevant supporting copies. Financial statements for a proposed collection alternative are not required with the initial Form 12153, but early submission may help resolve the case.
Use this decision table for routing and timing
| Notice received | CDP deadline | Equivalent deadline | Levy protection | Statute suspension | Tax Court option |
|---|---|---|---|---|---|
| Qualifying levy CDP notice | Generally postmarked by the 30th day after the notice | One year after the CDP levy notice | Generally, with statutory exceptions | Yes if timely CDP | Timely petition after the CDP determination, following its deadline |
| Qualifying lien CDP notice | By the date shown, after the five-business-day notice period and 30-day request period | One year plus five business days after NFTL filing | Levy generally held during the related timely CDP process; check exceptions | Yes if timely CDP | Timely petition after the CDP determination, following its deadline |
| Equivalent filing | Not applicable | See notice type above | No | No | No |
Mail to the address in the notice's hearing-request section, which will route the form to the correct IRS Independent Office of Appeals territory. Sending it to the payment address, a local office, or the generic Appeals address listed on IRS.gov will delay assignment and may jeopardize your deadline if forwarding takes longer than expected.
Prepare this submission checklist
- [ ] Form 12153 signed and dated by taxpayer(s) or authorized representative
- [ ] Copy of the CDP or levy/lien notice attached
- [ ] Reasons for disagreement stated in section 8
- [ ] Proposed collection alternatives listed in section 9 if any
- [ ] Form 2848 attached if representative signs and POA not already on file
- [ ] Envelope addressed to the hearing-request address printed on the notice
- [ ] Postmark or certificate of mailing obtained before the printed deadline
- [ ] Retained copy of entire submission and mailing proof for your records
A Collection Appeals Program request uses Form 9423 under its own deadlines and routing; it is a separate procedure and does not substitute for a Form 12153 hearing request. Do not confuse the CDP hearing with audit reconsideration, which asks the IRS to reexamine an already assessed liability using new evidence outside the Appeals process.
Reference these official IRS resources
Read the current Form 12153 and instructions, Publication 1660 on Collection Appeal Rights, and IRM 5.19.8. These documents provide the statutory framework and procedural details that control your hearing rights.
What happens if I miss the CDP deadline but file within the equivalent-hearing window?
A qualifying, timely equivalent-hearing request can lead to Appeals review of the issues raised, but the IRS may continue levy action during and after the hearing, the collection statute will keep running, and you cannot petition Tax Court to review the Appeals determination. File timely to preserve all protections.
Can I challenge the underlying tax liability in a CDP hearing?
Underlying-liability challenges are limited by whether you received a statutory notice of deficiency or otherwise had an opportunity to dispute the liability. Review those restrictions and any earlier proceedings before assuming Appeals can reconsider the amount.
Do I need to pay anything or submit financial statements with Form 12153?
No payment or financial documentation is required to request the hearing. Financial statements become relevant only if you propose an installment agreement, offer in compromise, or currently-not-collectible status, and Appeals will request them during the hearing process if needed to evaluate your proposal.
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