What is the difference between a CDP hearing and an Equivalent Hearing?

A timely CDP hearing (filed within 30 days of the qualifying notice) stops most IRS levy action while the hearing is pending and preserves your right to petition the U.S. Tax Court if you disagree with the Appeals decision. An Equivalent Hearing can be requested within one year of the qualifying notice if you missed the 30-day window, but it does not stop levy action and does not give you Tax Court appeal rights. An Equivalent Hearing is better than nothing but significantly weaker than a timely CDP hearing.

What can I raise during a CDP hearing?

During a CDP hearing, you can propose collection alternatives (installment agreement, Offer in Compromise, Currently Not Collectible status, or hardship relief), challenge the appropriateness of the collection action, request lien relief, and — in limited circumstances where you did not have a prior opportunity — dispute the underlying tax liability. The Appeals officer is required to be independent of the collection function and must consider your financial circumstances and proposed alternatives.

Does filing a CDP request stop the Collection Statute Expiration Date clock?

Yes. Filing a timely CDP hearing request tolls (pauses) the Collection Statute Expiration Date (CSED) — the IRS's 10-year collection deadline. The CSED is paused for the duration of the CDP hearing process. If you instead file an Equivalent Hearing request (outside the 30-day window), the CSED clock continues running and is not tolled. This difference is significant for taxpayers with older debts approaching the CSED.

What is a Collection Due Process (CDP) hearing?