Direct answer
A timely Collection Due Process request generally stops the IRS from proceeding with the levy that is the subject of the hearing for the covered tax periods. The protection normally continues until the Appeals determination becomes final, the taxpayer withdraws the request, or any timely judicial review ends.
Use the exact deadline and hearing-request address on the CDP notice. Merely calling the IRS, proposing a payment plan, or mailing Form 12153 to the wrong destination may not preserve the deadline.
What the suspension covers
The suspension applies to the levy action and tax periods properly included in the timely request. It does not automatically cover a different tax period, a different taxpayer, or a collection action not identified in the notice.
A timely CDP request also suspends the collection statute for the affected liability. That can extend the time the IRS has to collect after the hearing ends.
What it does not automatically stop
- The IRS may still file a Notice of Federal Tax Lien; Form 12153 expressly warns that a levy-hearing request does not prohibit lien filing.
- A lien-only CDP hearing does not itself prohibit levy in the same way as a timely levy-hearing request, although the IRS states that it normally does not levy while the lien hearing is pending.
- Federal law contains exceptions for certain levies, including specified jeopardy, state-refund, federal-contractor, and disqualified-employment-tax situations.
- The request does not erase the tax balance, stop penalties and interest, or approve a collection alternative.
If the request is late
An equivalent hearing may still be available within the period stated on Form 12153, but the IRS may continue levy action and the collection statute is not suspended. The Appeals decision from an equivalent hearing ordinarily cannot be reviewed by the U.S. Tax Court.
If the request may be late because the notice was delayed or circumstances were extraordinary and beyond your control, preserve the envelope and proof, file immediately, and explain the facts. Timeliness is a case-specific determination.
If money or property was already taken
Filing Form 12153 does not by itself guarantee the return of funds or property already collected. Raise any dispute about an improper levy, hardship, or incorrectly applied payment immediately with the IRS office and Appeals. Separate levy-release or refund rules may apply.
Recommended action
Submit the signed Form 12153 to the address or approved channel on the notice before its file-by date, include the notice, list every relevant period, state the reasons for disagreement, and keep proof. Continue current tax compliance and prepare financial information if you are proposing a payment plan, offer in compromise, or currently-not-collectible treatment.