IRM 8.22.4 Collection Due Process Appeals Program Specialist in Chicago, IL

IRM 8.22.4 explains Collection Due Process (CDP) and equivalent-hearing procedures. Hearing rights, filing dates and collection restrictions depend on the notice and tax periods involved.

Source checked: 2026-10-13 · Official IRS manual

The IRM is internal IRS procedural guidance, not the tax law. This selected reference is educational, not a complete legal opinion. Verify current law, guidance and case-specific deadlines.

Statutory foundation IRC §§ 6320 and 6330 govern lien and levy CDP hearing rights. IRC § 6330(c) addresses issues considered by Appeals; § 6330(e) addresses suspension rules. Exceptions must be checked.

Notice and timing Lien and levy notices use different timing rules. Section 6320 requires notice of an NFTL filing within five business days, while section 6330 generally requires notice of the right to a hearing not less than 30 days before the first levy for a period. The date printed on the actual notice is essential to determining the response deadline.

Limits and exceptions Do not assume that any appeal stops every collection action. The IRM lists exceptions to pre-levy hearings, and an equivalent hearing does not carry all the statutory consequences of a timely CDP hearing. Other tax periods may be treated differently.

Scope of review Appeals considers required verification, issues properly raised and the balance between efficient collection and intrusiveness. Eligibility to dispute the underlying liability has separate limitations.