The Trigger
The IRS sends a Final Notice of Intent to Levy or a Notice of Federal Tax Lien Filing. Each notice includes a 30-day deadline to request a CDP hearing. Meeting that deadline suspends collection and preserves Tax Court access. Missing it means you can only get an equivalent hearing with fewer protections.
What You Can Raise
Challenge the underlying liability, propose collection alternatives, raise spousal defenses, or challenge the IRS's procedural compliance. The Appeals officer must consider whether the collection action balances efficient collection with taxpayer rights.
The CDP hearing is your statutory check on IRS collection power. Never let the 30-day deadline pass without acting.
This guide is general information about federal tax law, not legal advice for your situation. Reading it does not create an attorney-client relationship.