Collection-Due-Process (CDP) Hearings
Collection Due Process hearings are an opportunity for the taxpayer at the federal level to receive Appeals review of liens or proposed levies. They are an important procedural device for taxpayers to avoid erroneous collection, or collection that creates a hardship. An unfavorable Collection Due Process hearing result may also trigger U.S. Tax Court review, in some circumstances even review of the ‘merits’ of the underlying tax.
Ignoring the Notice of Lien or Final Notice of Intent to Levy at the federal level, i.e. not filing a Collection Due Process hearing request, can have serious later procedural consequences on the case.