If you received an IRS Final Notice of Intent to Levy or a notice about a federal tax lien filing, the phrase Collection Due Process, often shortened to CDP, can feel technical and easy to ignore. In practice, it is one of the most important procedural protections in the IRS collection system. A timely CDP request can pause certain levy activity, move the dispute to the IRS Independent Office of Appeals, and create a path to court review in the U.S. Tax Court after Appeals issues a determination. 26 U.S.C. § 6330 and the IRS’s own CDP FAQs describe that framework.
This post explains what CDP is, when hearing rights arise, what collection alternatives may be raised, and how CDP fits into levy defense. If you want the broader landscape first, it may help to start with our guide to IRS tax disputes and defense options across audits, debt, appeals, Tax Court, and criminal exposure. In this post you’ll learn how the process works, what issues Appeals often considers, and where taxpayers sometimes lose important review rights.
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Collection Due Process is the procedure Congress created to give taxpayers a chance to challenge certain IRS collection actions before or just after they happen. Under federal law, the IRS generally has to give written notice and an opportunity for a hearing before levy, and after filing a Notice of Federal Tax Lien, with specific timing rules depending on the action involved. The hearing is handled by the IRS Independent Office of Appeals, not the collection function pursuing the account. 26 U.S.C. § 6330; IRS Appeals Overview.
For a levy case, the IRS commonly uses Letter 1058 or LT11 to notify the taxpayer that levy is being proposed and that a CDP hearing may be requested within 30 days from the date of the letter. The IRS explains this on its page about letters and notices offering an appeal opportunity. For lien cases, the IRS sends notice after the filing of the Notice of Federal Tax Lien, and the 30-day CDP period generally begins after the required post-filing notice period described in IRS guidance. IRS Publication 1660; TAS Form 12153 Overview.
If you want a more foundational walkthrough of the mechanics, our article on how CDP hearings work and what IRS enforcement rights look like in plain English goes deeper into the basics.
A levy is not just a warning letter. The IRS states that it may levy wages, bank accounts, Social Security benefits, retirement income, and in some cases seize physical property and apply future refunds against the debt. That makes CDP especially important in levy defense because a timely request may suspend levy action while Appeals considers the case, subject to exceptions in the statute and regulations. IRS Topic No. 201; 26 U.S.C. § 6330(e).
In general terms, CDP matters for three reasons:
For readers focused on procedure, our post about asking for the hearing before the deadline runs out breaks down timing in more detail.
CDP rights typically arise in two collection settings: