File first; continue preparing second
Do not miss the hearing deadline while collecting every possible document. Submit a complete, signed request with the required reasons and periods by the notice’s file-by date, then promptly provide additional evidence requested by Appeals.
1. Verify the notice
- The letter expressly states a right to a hearing under IRC 6320 or 6330.
- The taxpayer name and address are correct.
- The notice identifies lien, levy, or both.
- The tax form and periods are recorded.
- The exact request-by date is written on your calendar.
- The hearing-request address, fax, or approved upload route is copied exactly.
2. Preserve delivery evidence
- Keep the entire notice and every enclosure.
- Keep the envelope showing the postmark.
- Record the actual date received.
- If delivery was late, save evidence and explain it without delaying the request.
3. Use the current form
- Form 12153 revision July 2022, or the current replacement shown by the IRS.
- Form 12153 (SP) if completing the official Spanish version.
- Correct lien and/or levy boxes marked.
- Equivalent-hearing box considered only if the CDP request may be late.
- Copy of each notice attached.
4. Identify the case precisely
- Taxpayer names match the notice.
- Tax types, form numbers, and tax periods match.
- Every period to be reviewed is included.
- Both joint taxpayers sign when the form requires both signatures.
- An authorized representative includes the correct Form 2848 when needed.
5. State every issue
- Incorrectly applied payment or account error.
- Bankruptcy discharge issue.
- Innocent-spouse claim, when applicable.
- Lien withdrawal, discharge, or subordination request.
- Economic hardship or inability to pay.
- Installment agreement, offer in compromise, or other collection alternative.
- Underlying-liability dispute only when there was no prior opportunity to dispute it.
- A concise explanation and supporting document for each issue.
6. Prepare financial and compliance records
- Required returns filed or a plan to become current.
- Current estimated payments and federal tax deposits addressed.
- Form 433-A for an individual or Form 433-B for a business when Appeals needs financial information.
- Recent income, expense, bank, asset, debt, and household records.
- A specific affordable proposal rather than a general statement that payment is difficult.
7. Submit correctly
- Signed and dated request.
- Sent to the hearing-request address on the CDP notice, not the payment address.
- Approved fax or electronic route used only when the notice or IRS employee authorizes it.
- Complete copy retained.
- Postmark, certified-mail receipt, fax confirmation, upload receipt, or hand-delivery proof retained.
8. Prepare for Appeals
- Organize the notice, Form 12153, account records, returns, financial forms, and evidence by issue.
- Explain the requested outcome and why it is appropriate.
- Respond promptly to requests from the settlement officer.
- Continue current filing and payment obligations.
- Review any Collection comments on new evidence and respond when needed.
9. Track the decision
- Save the Notice of Determination or equivalent-hearing decision letter.
- Confirm that any agreed collection alternative is documented.
- If the IRS Collection function does not follow the determination, contact Appeals as instructed.
- If considering Tax Court review of a CDP determination, act immediately; the general filing period is 30 days from mailing of the determination.
- Obtain qualified tax or legal help for court filing, bankruptcy, joint liability, or complex collection issues.