Form 12153: Request CDP Hearing

When the IRS issues a final notice of intent to levy (LT11 from the Field Collection function, or Letter 1058 from the Automated Collection System), or files a Notice of Federal Tax Lien (Letter 3172), you have exactly 30 calendar days from the date on the notice to file Form 12153 and request a Collection Due Process hearing. This deadline is jurisdictional — if your Form 12153 arrives at the IRS even one day late, you lose CDP hearing rights. You may still qualify for an Equivalent Hearing (with no judicial review rights) if filed within one year, but the powerful CDP protections — levy suspension, an independent Appeals officer, and the right to petition the Tax Court if you disagree with the Appeals decision — are lost.

Always send Form 12153 by certified mail, return receipt requested. Keep the certified mail receipt and the return receipt (green card) as proof of timely filing. The IRS may deny a CDP hearing if it claims the Form 12153 was filed late — your certified mail proof is your defense. Fax filing with a fax confirmation sheet is also acceptable and preserves a timestamp.