Collection Due Process Hearing
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1 263 Collection Due Process (CDP) Statutory Right A gift from the IRS Restructuring and Reform Act of Lien IRC Levy IRC 6330
2 263
3 264 Critical Issues of CDP Use it or lose it 30 days to REQUEST from date of notice of right Original notice of levy Original notice of filing of a federal tax lien OR End up with equivalency hearing
4 264 4
5 264 Exercise Care and Thoughtfulness Prior to requesting CDP request Tax Relief and Health Care Act of 2006 made the filing of frivolous returns subject to a $5,000 penalty, this includes Form 12153
6 265 Employment Tax Restriction The taxpayer may only have a hearing once every two years regarding levy/liens filed in employment tax cases.
7 266
8 265 During consideration of CDP ALL collection activity is suspended BUT The statute of limitations is extended as well plus 30 days
9 265 D. Filing the request on Form Discuss ALL reasons that taxpayers disagrees with action taken by IRS 1. Appropriateness of action 2. Collection alternatives 3. Spousal Issues 4. Tax Liability Is it real IF taxpayer was not afforded opportunity to participate 5. Any other relevant reason
10 266
11 267
12 267 Any and ALL reasons that may apply should be addressed, failure to do so could make them irrelevant at the hearing
13 268 The period from the filing of the Form until the hearing can be as long as 6 9 months but usually 3 months During which period the taxpayer can (should) continue to negotiate with the IRS IRS will request withdrawal of CDP request if the taxpayer comes to a settlement regarding the issue
14 268 Form 12256
15 269 Form 12256
16 270
17 271 B. 2. Location of CDP Conference Telephone Face to Face
18 271
19 271
20 271
21 272
22 272 Some problems with Collection Due Process Hearings That a decision was issued is on the transcript however the hearing officer s decision often is missing from the file get it to the functionary you are working with Your taxpayer s CDP rights are VERY VALUABLE PROTECT them with all your might
23 Opportunities regarding the CDP hearing File an OIC (Offer in Compromise) Obtaining releases of FTL
24 Collection Appeals Program (CAP) 1. Notice of Federal Tax Lien 2. Notice of Levy 3. Seizure of Property 4. Denial or Termination of IA 5. Denied Offer in Compromise 6. Proposed Trust Fund Recovery Penalty 7. Misc Penalty Proposals if Abatement Denied
25 Collection Appeals Program (CAP) Filing a an appeal should be done through the IRS employee handling the case indicating the taxpayer is exercising the CAP rights 274 The employee must make the referral to a manager and if unresolved file Form 9423
26 Collection Appeals Program (CAP) Form 9423 must be filed within two ten days of conference with collection manager, except for denial of IA which has 30 days. 2. Disagreement is not a basis, solutions must be offered 3. Enforcement is stayed during consideration 4. Decisions are binding on IRS and TAXPAYER * NO JUDICIAL REVIEW IS AVAILABLE
27 Collection Appeals Program (CAP) Scheduling the Conference A. Discover any particular concerns the appeals officer may have B. Request and prepare a response to the examiner s rebuttal C. Look at case file and if not provided make a FOIA request for administrative file. 275
28 Conference Strategies It is not about winning it is about settling the matter There are no rules of evidence submit everything that supports your case When appropriate submit a written offer Collection Appeals Program (CAP)
29 Collection Appeals Program (CAP)
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