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Catalog Number 26685D www.irs.gov
Form
12153 (Rev. 7-2022)
Important Things to Know for a CDP or Equivalent Hearing
Your timely request for a CDP hearing will prohibit levy action in most cases. A timely request for a CDP hearing will also suspend the
10-year period IRS has, by law, to collect your taxes. Both the prohibition on levy and the suspension of the 10-year period will last until
the determination Appeals makes about your disagreement is final. The amount of time the suspension is in effect will be added to the
time remaining in the 10-year period. For example, if the 10-year period is suspended for six months, the time left in the period the IRS
has to collect taxes will be extended by six months. You can go to court to appeal the CDP determination Appeals makes about your
disagreement.
If you want a hearing with Appeals after the deadline for requesting a timely CDP hearing has passed, you must check the box in item
2. In this case you will receive an equivalent hearing, which is the same as a CDP hearing except it does not prohibit levy or
suspend the 10-year period for collecting your taxes; also, you cannot go to court to contest Appeals' decision about your
disagreement. You must request an equivalent hearing within the following timeframe:
• Lien Notice—one year plus five business days from the filing date of the Federal Tax Lien.
• Levy Notice—one year from the date of the CDP levy notice.
Keep a copy of your hearing request and proof of the date you sent it.
Your request for a CDP levy hearing, whether timely or equivalent, does not prohibit the IRS from filing a notice of federal tax lien.
You will have to explain your reason for requesting a hearing when you make your request. Below are examples of reasons for
requesting a hearing.
“I am not liable for (I don't owe) all or part of the taxes.” You can generally raise a disagreement about the amount you owe if you
did not receive a deficiency notice for the liability or if you have not had another prior opportunity for Appeals or a court to consider your
disagreement with the amount you owe. A deficiency notice is a notice explaining why you owe taxes—it gives you the right to
challenge in court, within a specific time frame, the additional tax the IRS says you owe.
Penalty appeal—Appeals may remove all or part of the penalties if you have a reasonable cause for not paying or
not filing on time. For what is reasonable cause to remove penalties, see Notice 746, Information About Your
Notice, Penalty and Interest, at https://www.irs.gov/pub/irs-pdf/n746.pdf, or by scanning this QR code.
Innocent Spouse Relief - You believe that your spouse or former spouse is the only one responsible for all or a part
of the tax liability. Learn more about this request at https://www.irs.gov/businesses/small-businesses-self-employed/
innocent-spouse-relief, or by scanning this QR code. You must complete Form 8857, Request for Innocent Spouse
Relief, for an Innocent Spouse request to be considered.
Prior bankruptcy: You may have received a prior bankruptcy discharge and your taxes were not excepted from the
discharge. Note that even if your taxes were discharged, your pre-bankruptcy property may remain subject to a tax
lien if the property was excluded from the bankruptcy or if a notice of the lien was filed before the bankruptcy. Learn
more about bankruptcy at https://www.irs.gov/businesses/small-businesses-self-employed/declaring-bankruptcy, or
by scanning this QR code.
"I've made payments that were not applied to my taxes." You may disagree with the amount the IRS says you have or have not
paid.
If You Want to Propose a Lien Resolution – For the filing of a Notice of Federal Tax Lien (NFTL) against your property, choose
a lien resolution and submit appropriate documentation with this form.
Withdrawal: When you request a withdrawal of the NFTL, you are asking the IRS to remove the NFTL information from public records
because you believe the NFTL should not have been filed.
Subordination: When you request a subordination, you are asking the IRS to make a Federal Tax Lien secondary to a non-IRS lien.
Release: You can get a Federal Tax Lien released if you pay your taxes in full or complete the terms of an accepted Offer-in-
Compromise.
Discharge: When you request a discharge, you are asking the IRS to remove a Federal Tax Lien from a specific property.
Learn more about the NFTL, what may be the right alternative to your issue, and what documentation to include with
your Form 12153 at https://www.irs.gov/businesses/small-businesses-self-employed/understanding-a-federal-tax-lien,
or by scanning this QR Code: